Terms and conditions of use EU

This service (referred to henceforth as “App”) is provided by ASSA ABLOY Switzerland Ltd., headquarters Untere Schwandenstrasse 22, CH-8805 Richterswil, E-mail: marketing.chriw@assaabloy.com (referred to henceforth as “we” or “us”) as the responsible party in accordance with the applicable data protection law.

With the app, we enable you to access and display the following information:

• Product descriptions
• Installation help (videos)
• Ordering of marketing material

As you use the app, we process personal information relating to you. Personal information refers to all information relating to an identified or identifiable natural person. Because protecting your privacy while you use the app is important to us, we have outlined the personal information processed by us when you use the app below and how we use this information. We will also inform you of the legal framework for processing your information and, if the processing is necessary to fulfil our justified interests, we will also inform you of our justified interests.

You can view the privacy statement at any time under the menu option “[FAQ]” in the app.

Specific information is processed automatically as soon as you use the app. Exactly which pieces of personal information are processed is listed below:

Specific required information is transferred to the selected App Store (e.g. Google Play or Apple App Store) when you download the app, in particular the user name, e-mail address, customer number for your account, the time of the download, payment information and the individual device code, can be processed. This information is only processed by the relevant App Store and is outside our sphere of influence.

Registration in the App marketplace of the relevant provider (Apple Inc., Cupertino, USA, for iOS devices (privacy statement: https://www.apple.com/privacy/) and Google Limited, Dublin, Ireland or Google LLC, Mountain View, USA, for Android devices (privacy statement: https://policies.google.com/privacy?hl=en) is required under these conditions.

As you use the app, we collect specific information automatically that is required for using the app. This includes: internal device ID, the version of your operating system, the time of access.

This information is sent to us automatically, but not saved, (1) in order to provide the service and the associated functions; (2) to improve the functions and features of the app and (3) to prevent and remedy misuse and malfunctions. This processing of information is justified by the fact that (1) the processing is required in order to fulfil the contract between you as the affected party and us in accordance with Article 6(1)(b) GDPR or (2) because we have a justified interest in ensuring the function and fault-free operation of the app and providing a market-oriented service that fulfils the interests, that outweighs your rights and interests in the protection of your personal information in accordance with Article 6(1)(f) GDPR.

When you create a user account or log in, we use your access details (e-mail address and password) to grant you access to your user account to manage this. Compulsory information provided during the registration, such as your first name, surname, company, e-mail addresses, customer number, are marked with an asterisk and are required for signing the usage contract. You cannot create a user account without providing this information.

We use the compulsory information to authenticate you during login and to process requests to reset your password. The information provided by you during the registration process or during login is processed and used by us (1) to verify your authorization to manage the user account; (2) to implement the terms and condition of use for the app, as well as all associated rights and obligations, and (3) to contact you with technical or legal information, updates, security notifications or other messages relating to the management of your user account, for example.

This processing of information is justified by the fact that (1) the processing is required in order to fulfil the contract between you as the affected party and us in accordance with Article 6(1)( b) GDPR or (2) because we have a justified interest in ensuring the function and fault-free operation of the app, that outweighs your rights and interests in the protection of your personal information in accordance with Article 6(1)(f) GDPR.

While using the app, you can enter, manage and process various information tasks and activities. This information includes, in particular, data relating to your access to documents provided and the management of your shopping basket.

The app also requires the following authorizations:

• Internet access: This is required to save your entries on our servers.
• The camera is not accessed.

The usage data is processed and used for the purpose of providing the service. This processing of information is justified by the fact that the processing is required in order to fulfil the contract between you as the affected party and us in accordance with Article 6(1)(b) GDPR for using the app.

In addition to the concrete cases outlined in this privacy statement, your personal information shall only be passed on without your express prior permissions where this is permitted or required by law. This may be the case, for example, where the processing is required to protect the vital interests of the user or another natural person.

2.1     The information entered during the registration is transferred internally within our ASSA ABLOY company group for administrative purposes, including joint customer services to the extent necessary.

Any forwarding of the personal information is justified by the fact that we have a justified interest in passing on the information within our company group for administrative purposes, which is not outweighed by your rights and interests in the protection of your personal information in accordance with Article 6(1)(f) GDPR.

2.2     Where necessary to clarify unlawful use or misuse of the app, or as part of prosecution proceedings, personal information will be handed over to the law enforcement authorities or other authorities and forwarded to affected third parties or legal advisers where applicable. This shall only take place, however, if there is evidence of unlawful activities or misuse. The information may also be forwarded for the purposes of enforcing terms and conditions of use or other legal claims. We are also legally obliged to share information at the request of specific public authorities. These are law enforcement authorities, authorities pursuing administrative offences incurring a fine and financial authorities.

Any forwarding of the personal information is justified by the fact that (1) the processing is necessary to fulfil a legal obligation which we are bound by in accordance with Article 6(1)(f) GDPR in conjunction with national laws for passing on information to law enforcement agencies or (2) because we have a justified interest in forwarding the information to the specified third parties where there is evidence of misuse or to enforce our terms and conditions of use, other conditions or legal claims, which is not outweighed by your rights and interests in the protection of your personal information in accordance with Article 6(1)(f) GDPR.

2.3.    For the provision of our service, we rely on contractually bound companies of the ASSA ABLOY company group, as well as external companies and service providers.

Any forwarding of the personal information is justified by the fact that we have a justified interest in passing on the information within our company group for administrative purposes, which is not outweighed by your rights and interests in the protection of your personal information in accordance with Article 6(1)(f) GDPR and (2) by the fact that we have selected our external companies and service providers as processors in accordance with Article 28 (1) GDPR extremely carefully, monitor them regularly and have a contractual agreement with them that they must process all personal information in accordance with our instructions.

2.4     As part of the ongoing development of our business, the structure of our company may change as a result of changes in the legal form or due to the formation, purchase or sale of subsidiaries, company divisions or components. In the event of transactions like these, the customer information may be passed on together with the part of the company being transferred. Whenever personal information is passed on to third parties in the specified scope, we ensure that this takes place in accordance with this privacy statement and the applicable data protection laws.

Any forwarding of the personal information is justified by the fact that we have a justified interest is adapting our company form to the economic and legal conditions as required, which is not outweighed by your rights and interests in the protection of your personal information in accordance with Article 6(1)(f) GDPR.

We also process data in countries outside the European Union (EU) and the European Economic Area (“EEA”). This also includes Switzerland (headquarters of the responsible party, see preamble).

Processing of your personal information for purposes other than those listed shall only take place where legally permitted or if you have agreed to the amended purpose of the data processing. If the information is to be processed for purposes other than those for which the information was originally collected, we will inform you of these other purposes beforehand and provide you with all other significant information relating to this change.

We will delete or make your personal information anonymous as soon as it is no longer required for the purposes for which it was collected or used according to the clauses outline above. We will usually only save your personal information for the duration of use or for the term of the contract for the app, plus a period of 14 days during which we keep backup copies after the information is deleted, providing this information is not required for longer for legal proceedings or to safeguard, implement or enforce legal claims.

Specific information in this privacy statement or legal regulations for storing and deleting personal information, in particular information that must be kept for tax law reasons, remains unaffected.

6.1     Right to information

You have the right to request details of the personal information relating to you that is processed by us in accordance with Art. 15 GDPR.

6.2     Right to have incorrect information corrected

You have the right to request that incorrect personal information relating to you be corrected immediately.

6.3     Right to deletion

You can request that personal information relating to you be deleted in accordance with Art. 17 GDPR. Your right to deletion depends, among other things, on whether the information relating to you is still required to fulfil our legal obligations.

6.4     Right to restrict the processing of the information

Under Art. 18 GDPR, you have the right to restrict the processing of the information relating to you.

6.5     Right to data portability

You have the right to receive the personal information provided by you from us in a structured, common, machine-legible format in accordance with Art. 20 GDPR. To exert your right to data portability, please get in touch via the contact addresses provided below.

In accordance with Art. 21 GDPR, you have the right to object to the processing of information relating to you as a result of a particular situation. We cannot always fulfil this request, however. 

You also have the right to consult a regulatory authority.

If you have questions or comments relating to our handling of your personal information or if you would like to exert the rights as an affected person listed under clauses 6 and 7, please send an e-mail to datenschutz.ch@assaabloy.com or write to the address listed in the preamble.

We always keep this privacy statement up to date. We therefore reserve the right to make changes to the collection, processing or use of your information from time to time. The latest version of the privacy statement is available under “[FAQ]” within the app.

Status: 29 April 2020