Trade Compliance Privacy Notice

References to "Company" and "ASSA ABLOY" in this document have the meaning that those terms are given in the associated Information Request Form.

ASSA ABLOY ("we", "us") is considering engaging in business with the Company. Prior to entering a business relationship, we need to conduct screenings of certain individuals associated with the Company for trade compliance purposes including export control and sanctions. We may also conduct additional screenings during our business relationship. You receive this privacy notice since your name will be subject to such screening.

ASSA ABLOY is committed to protecting your personal data. This privacy notice describes how ASSA ABLOY processes and uses the personal data relating to you. It also describes how you can contact us if you have additional questions regarding our processing of your personal data.

ASSA ABLOY has obtained personal data relating to you in your capacity as:

• Contact person, owner, board member, or director of the Company.
• Owner of JV partner; or
• Contact person, owner, board member, or director of the end-user.

The personal data has been obtained from the Company and related parties who may be doing business with the Company as more fully set out in the Information Request Form, and/or from third parties (including as set out in our Privacy Policy).

The personal data collected may include:

• Name
• Contact details
• Address
• Role
• Ownership percentage

If your name appears on any of the export control and sanctions lists we screen against, we may also process personal data relating to criminal convictions and offences.

Since you are an individual associated with the Company, ASSA ABLOY will process your personal data for the purpose of carrying out export control and sanctions screening. In practice, this means that your name will be checked against third party risk assessment tools incorporating sanctions lists adopted by regulatory authorities such as EU and the UN.

ASSA ABLOY’s processing of your personal data as described above is necessary for us to comply with legal obligations under applicable export control and sanctions laws.

We will also process your personal data for the purpose of documenting the result of the screening exercise. The processing of your personal data for the foregoing purposes is based on the legitimate interest of ASSA ABLOY to comply with applicable regulatory requirements and to mitigate third party risk. In cases where personal data relating to criminal convictions and offences is documented in the results, such processing is based on ASSA ABLOY’s legal obligations under applicable export control and sanctions laws.

ASSA ABLOY may transfer your personal data to other ASSA ABLOY group companies and suppliers. Information on our group companies and where they are located can be found on www.assaabloy.com. Since these countries may have a lower level of protection than that within the EU/EEA, ASSA ABLOY uses standard contractual clauses approved by the European Commission when transferring personal data to ensure a sufficient level of protection.

The personal data that is collected and stored is exclusively used by companies within the ASSA ABLOY group, except in the following cases where we submit the data to third parties:

• When required by law,
• To a buyer or potential future buyer of our business, and/or
• To service providers appointed by ASSA ABLOY who provides services necessary for conducting the export control and sanctions screening and associated services.

ASSA ABLOY will take measures to protect all personal data transferred to such third parties, or that has been transferred to other countries, in accordance with applicable data protection laws and as stated above.

ASSA ABLOY will store the personal data as long as it is necessary to fulfil the purpose for which the data has been collected and any applicable regulatory purposes. This means that ASSA ABLOY will delete your personal data when such data is no longer necessary to ensure compliance with applicable export control and sanctions laws, and no other regulatory requirement to retain the data applies. We may also retain it for a period as necessary for appropriate/lawful record keeping purposes.

You may at any time request the rectification or erasure of your personal data. You have the right to request a copy of your personal data from our record. You have the right to request a limitation of the use of your personal data (for example if you deem the data to be incorrect) or the termination of use of your personal data.

ASSA ABLOY is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to ASSA ABLOY Data Protection Manager by email to Privacy.PNEA@ASSAABLOY.com.

Please also refer to the ASSA ABLOY privacy policy available on the ASSA ABLOY website for details such as if you have questions, objections, or complaints regarding how we process your personal data.

This privacy notice was last updated on 20 September 2023.