Privacy notice

At ASSA ABLOY Global Solutions AB and its related affiliates, we believe it is important to protect the privacy of our customers and partners. This Privacy Notice explains how we collect, use, and protect any information that we collect from you, when and to whom we disclose such information and the choices you have about the use of that information. The Privacy Notice is below. We encourage you to review this notice in its entirety.

ASSA ABLOY Global Solutions AB, a company registered in Sweden under number 556666-0618, at Förmansvägen 11, 117 43, Stockholm is responsible for the processing of your personal data.

1.1 What personal data we collect

We collect and store personal data from you regarding:

Accounts, responding to your request and support

- When you request information from us: your company profile, your name, title, and contact information which may include address, country information, email and/or telephone number which you submit in order to obtain information from us and the products or services you would like to learn about;

- When you provide your consent to send you marketing information or other information requested;

- When you create an account to order from us: your company profile, your name, title, and contact information which may include address, email and/or telephone number and delivery details as well as any other information required to verify and fulfil the order and order history;

- When using our applications, which may include administration of one of our products unless otherwise noted: your company profile, your name, title, and contact information which may include address, email and/or telephone number, username and password and other information relevant to using the application in question;

- When you provide your consent and use our mobile access applications, we will collect your email address, property reservation information, and account information, electronic key, including username and password;

- To provide customer support on the products and services we provide we will need to collect contact information, which may include your customer number or property name, and information about the issues experienced;

Surveys and Trainings

- When completing a survey for us: your contact information and opinions and impressions of our services and products, unless an anonymous survey request. If anonymous, your responses will not be saved with your profile.

- When enrolling for training and completing training: your company profile, your name, title, and contact information which may include address, email and/or telephone number and all related transcript data including classes attended, completion rate, etc.

Websites, Applications and Services

- When you visit and use our websites, services, applications, or accept additional information: we collect your statistical and anonymous data from your browsing behavior and anonymous cookies. This includes referral information, your device and browser information, preferred language, pages visited, time spent on each page, links clicked for the purpose of providing and improving our services.

- When you visit our websites and accept the use of cookies: we collect IP information to derive geolocation information i.e. city area, which links you choose to click, user preferences i.e. what users do and don’t like on our website and device identifiers and this enables us to further improve our service with user feedback. This information is stored in pseudonymised user profiles for statistical reasons, which neither us or our service providers use to identify individual users.

- When you agree to the use of re-marketing, tracking cookies/technologies our ads may appear when you visit other web sites or platforms. For example, we may use Google Ads “remarketing” service to serve ads to you based on your prior use of our website. Remarketing displays relevant ads tailored to you based on what parts of our website you have viewed by placing a cookie on your device. The cookie is used to indicate, "This person visited this page, so show them ads relating to that page. We also collect information about our ad campaigns to understand how many times an ad has been shown to each user, how many times users has clicked on it. Our third party providers can further associate the above information with your consent with your advertising profile and preferences that includes your advertising ID such as Android Advertising ID (AAID) and Apple’s Identifier for Advertisers (IDFA).

If you do not wish to participate in our Google Ad remarketing, you can opt out by visiting Google's Ads Preferences Manager. You can also opt out of third-party vendor's use of cookies by visiting this link.

- When interacting with us on social media including Facebook, YouTube, LinkedIn, Twitter, and Google+: We may collect your company profiles, contact information, other related information and basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings; however, they might include the above and additional available details.

Data from Children

- Our websites, apps, products and interactions are meant for adults. We do not collect Personal Information from any person that we know to be under the age of sixteen (16) without permission from a parent or guardian.

- If we become aware that personal information that has been submitted to us relates to a child in contravention of any applicable laws and regulations we will use reasonable efforts to delete their personal information as soon as possible. Where deletion is not possible ASSA ABLOY Global Solutions will ensure this personal information is not used further for any purpose, nor disclosed further to any third party. Any parent or guardian can contact us using the details in the contact us section regarding any processing of personal information relating to their child.

Information we collect from third parties

- We may receive your personal data (including contact information) from your employer for purposes further defined below.

- We receive personal data when you use the services of our customers and partners, such as hotels, installation services, sales partners, etc.

- We may also receive information about you from other ASSA ABLOY group companies.

- We may receive your personal data from ASSA ABLOY Global Solutions services or products that you interact with.

- We may acquire data from third parties that includes information regarding projects in our area of business together with key project individuals. This information includes name, role and business contact details. When this occurs, we will notify you using the contact details available and provide the opportunity to object to using your data to provide legitimate business communications regarding our products and services.

1.2 Use of your personal data

How and why we use your data will depend on the service your use. Below explains the uses.

Why do we process this personal data?

● What is the legal basis for such processing?

To authorize access to our services.

● When requesting a service like setting up an account, training, using mobile services or our applications, or accessing customer support, certain personal data is necessary to ensure we can get in contact with you and provide what is requested. We also want to ensure you have a chance to review and accept any applicable terms and conditions.

To provide you with the information you request.

● Using your personal data in this way is necessary for us to respond to your request.

To manage your account, for example by sending you password reminders or notifications of changes to your account details.

● Using your personal data in this way is necessary for us to provide you with an online account and to respond to your request.

To fulfil your order where you have made a purchase from one our websites, to contact you about sales and as a part of our customer relation and support procedures.

● Using your personal data in this way is necessary for us to perform our contractual obligations where you have placed an order on this website.

To provide recommendations, for shoppers on our eStore.

● It is our legitimate interest to collect behavioral data of shoppers, such as which products the shoppers search, view, add to cart, and more. This data can then be used to provide recommendations.

To carry out statistical analysis about the use of the website and our services to better understand how they are used and make improvements.

● It is in our legitimate interest to look at this information to understand how our website is being used to manage and improve it. Since no sensitive personal data will be processed and the processing is limited, we have concluded that our legitimate interest to conduct the improvements and analysis takes precedence over your privacy interest.

To comply with legal requirements to which we are subject, such as tax or financial reporting requirements.

● Using your personal data in this way is necessary for us to comply with our legal obligations.

To better understand your interests and preferences, in order to provide you with an experience that is tailored to those interests and preferences.

● It is in our legitimate interest to look at the preferences that we derive from your browsing behavior so that we can personalise content and better meet your needs as a customer, provided this is in line with your marketing choices.

To better, understand your wishes, expectations and requirements in order to develop our activities, products and services, offerings, customer service and communications to you.

● It is in our legitimate interest to look at the feedback that we derive from your survey responses to enable good customer service and support, deal with your questions, correct erroneous data or dispatch information that you have requested. If we want to be able to identify an individual person in a survey, this is only done if expressly stated in the invitation to the survey.

To statistically analyse your feedback from surveys over time in order to develop and improve our activities, products and services, offerings, customer service and communications to you.

● It is in our legitimate interest to analyse the behavior and patterns of customers through the survey responses over time to be able to give you recommendations and adapted services based on the interests of others with similar behavior patterns. The survey may be sent to you again and we would then want to be able to compare results from the previous occasion to verify that we are improving.

To personalize and measure the effectiveness of advertising on our website and third party websites.

● With your consent, we use third party vendors re-marketing cookies, for example, Adroll and Google Ads to serve relevant advertisements on our marketing partners display network.

To further understand users’ needs, optimize services, enhance their experience and improve our services.

● With your consent, we enable cookies that allow us to better understand your experience and with your express consent, may link this data for further understanding.

To send you communications about relevant solutions, products and services, including updates which may be of interest, in accordance with your marketing preferences.

● We will only send you marketing materials where we have your consent, a contractual basis; or where we have a legitimate interest to keep you updated.

If you submit a question or a request on a social media platform to interact with you as requested.

● It is in our legitimate interests to use the personal data you share with us from these sources to provide information requested, improve the quality of our products and services, and engage in the conversations on those platforms. We will NOT use these mediums to provide unsolicited direct marketing.

Invite customers to register for our services i.e. support, eStore, or end-users to create a mobile key.

● It is our legitimate interest to invite customers to register for our services. Should the customer fail to activate their account or complete registration we will remove their account from our services.

To support our customer we sometimes need to simulate and troubleshoot an issue using a copy of their database from our products and services.

● It is our legitimate interest to provide support and with customer’s permission obtain a copy of the local database. This database contains personal data from our customers but also their customers. Once the issue is resolved, personal data is deleted.

To process pseudonymised data from customer databases for test purposes, investigate usage patterns, perform simulations to improve our products and services.

● It is our legitimate interest to improve test scenarios for our products and services, improve quality, identify improvements from usage patterns and shorten lead-time to market that ultimately benefit our customers as well.

To offer you guided solution selection tools to assist you with selecting the correct product or service.

● It is our legitimate interest to use your personal data to respond to your request.

1.3 Use of Artificial intelligence (AI)

We process your personal data using AI technologies to increase our efficiency and better serve your needs as our customer. We rely on Legitimate Interest for this processing, which in this context means that we have a business interest in using your data that is not overridden by your privacy rights. The use of AI enables us to offer faster and more accurate responses, and to provide tailored information that fits your preferences. This helps us analyze and anticipate your needs, allowing us to act proactively and ensure a better experience when interacting with our company.

We process personal data using AI, which includes your name, surname, contact information such as email and phone number, company details such as the company you work for and its address, and your job title as one of our customers, business partners, or a company representative interested in our products and services. This processing may further include information regarding products and services you are interested in or have acquired from us, information regarding installation, maintenance or support related topics, or other project tasks, as well as billing or other financial information from your company where we need a contact person.
We process the above personal data using AI in our IT systems, such as the CRM (Customer Relationship Management platform), Support platforms where we provide customer support, maintenance, or installation services regarding our offered solutions, as well as other related project tasks, the ERP (Enterprise Resource Planning) where we process billing and other financial information such as invoices related to your company, our eCommerce platform where we offer additional products linked to the services you have acquired from us, and our corporate website when interacting as a web visitor with our chatbot or submitting a website form.
It’s important to note that there is no automated decision-making performed by these AI technologies. Our employees follow internal requirements and directives for use of AI, ensuring its appropriate utilization in communications with you. Furthermore, should you directly interact with an AI system We will inform you of such interaction, unless this is reasonably obvious in the context of use.
You also have the right to opt out of AI processing of your personal data. If you wish to do so, please contact us through the provided contact methods. Please note opting out of AI processing may affect the speed and services we can provide.

1.4 Transfer of your personal data

We may transfer your personal data for the purposes set out above:

- To other companies within the ASSA ABLOY group;

- To third parties who provide services connected to our applications, surveys, web services, and the other purposes defined above.

- When required by law;

- To business partners;

- To vendors.

Some recipients may be located in countries outside the EU/European Economic Area (EEA).

As in some cases these countries have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data. These standard contractual clauses, as well as information on countries approved by the European Commission are available on International dimension of data protection (europa.eu)

We take measures to protect all personal data transferred to a third party, or to other countries, in accordance with applicable data protection laws and as stated above which includes a data processing agreement where required.

1.5 For how long will we store your personal data?

We store personal data for as long as necessary to fulfill the purpose for which the data has been collected unless a longer retention period is required or permitted by law. This means that we delete your personal data when such data is no longer necessary to process a request or an order, or to manage your account or our client relationship and when the required retention period has expired. The following is a list of retention periods for personal data relevant to this Privacy Notice.

Type of data stored

● How long is it stored?

Contact information you provide us in forms submission, contact request and events such as; Your name, email address, region/country and company name.

● Deleted 24 months after becoming inactive or after three email bounces.

Your responses in surveys that you participate in.

● Deleted 24 months after the end of the survey period. Aggregate data that can’t be tied to an individual may be stored longer.

Marketing preferences such as opt-in or opt-out to receive information and newsletters through email.

● Deleted 24 months after becoming inactive or after three email bounces.

Information related to our business relationship, such as data in orders and quotes, requirements that you provide us with and delivery information.

● For the duration of our business relationship and 5 years thereafter. Data may be stored longer when we are legally required to do so.

Application data collected from users of our mobile applications.

● Deleted after 24 months for active users or after becoming inactive.

Customer database copies related to support cases.

● Deleted within 6 months after the support case is resolved.

1.6 Your rights

In relation to the personal data that we hold about you, you have the right to:

- Request a copy of your personal data from our records;

- Ask that we correct or erase your personal data (though this may mean that we cannot process requests or orders, or that your account expires);

- Ask us to stop processing your personal data (for example as regards the use of the data to improve our website), or restrict how we process it (for example if you deem the data to be incorrect);

- Request the personal data used to provide you with information you requested, process an order, or manage your account or our relationship in a machine-readable format, which you are entitled to transfer to another data controller; and

- Withdraw your consent to us processing your data for marketing purposes at any time.

Requests to exercise your rights should be addressed to:

“Attn.: ASSA ABLOY Global Solutions Data Protection Manager”

Lodjursgatan 1

261 44 Landskrona

Sweden

e-Mail: privacy.globalsolutions@assaabloy.com

If you have a complaint regarding our processing of your personal data you are entitled to report this to the Swedish Data Protection Authority (IMY) at Box 8114, 104 20, Stockholm, Sweden. Details of the Swedish Data Protection Authority can be found here.

1.7 Changes to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, regulatory or operational requirements. We will notify users of any such changes (including when they will take effect). The latest version of our privacy notice is available through our website.

Your continued use of the digital service after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this privacy notice, you should stop using this digital service.

1.8 Cookies

A ‘cookie’ is a small text file containing information which is stored on your computer. We use cookies to ensure that we give you the best experience on our website which includes cookies from 3 parties. Some cookies may track your use of our webpage, show personalized content and targeted ads, analyze site traffic and understand where our audience comes from. To find out more read our Cookie Policy. For more information about how cookies work, please also refer to: www.allab o utcoo kies.o r g

1.9 Security

We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use include firewalls, data encryption, access and authorization controls. As a general best practice on the Internet, it is recommended that individuals take great care of their user accounts and do no share them. Also it is important to protect and secure your mobile device using the latest software with up to date security patches.