PRIVACY POLICY FOR MOBILE ACCESS

BACKGROUND

This Privacy Policy forms a part of the Mobile Access License and User Agreement and is part of the agreement between You and ASSA ABLOY Mobile Services AB (together with other relevant companies within the ASSA ABLOY group, collectively or individually (“We”, “Us” or “Our”)) for the Licensed Materials and Services (both as defined in the Mobile Access License and User Agreement) (the “Agreement”). 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.

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

A. The Data We and/or the Enterprise may Collect
B. Why We Collect the Data and Basis for the Collection
C. Who may We disclose Data to?
D. Period of Retention and Use
1. Transfer
2. Precautions
3. Children
4. Changes
5. Your rights in relation to Your Data
6. Contacts

WHAT THIS PRIVACY POLICY COVERS

The mobile access application may have been provided to You by one of Our existing customers (an “Enterprise”). In connection therewith, We provide You with the Licensed Material and Services on behalf of the Enterprise. Therefore, You should also bear in mind that, as Your use of the Licensed Materials and Services has been requested by an Enterprise, the Enterprise may also receive and use some or all of the Data, either directly from You or from Our systems.

The Enterprise will be collecting and/or using the Data independently of Us, and You agree that We are not responsible for the type of information that the Enterprise collects and/or uses about You, or how and why the Enterprise collects and/or uses the Data. The Enterprise is responsible for giving You a copy of its privacy policy which describes what information it collects and/or uses about You and why.

To the extent that We use Data for purposes which are not directly connected to providing You with the Licensed Material and Services (such as development of new products), We are responsible for the use of Your Data in accordance with applicable law instead of the Enterprise.

This privacy policy describes how We use Your Data both on behalf of the Enterprise and for Our own use.

A. THE DATA WE AND/OR THE ENTERPRISE MAY COLLECT

We and/or the Enterprise may collect the following Data:

  1. Your name, phone number, email address, ID and password, and other data which the Enterprise uses to identify You when making it possible for You to use the Service; 
  2. Technical data and related information about the Device being used for the Services, including unique push ID, operating system, application software and peripherals;
  3. Information related to the use and performance of the Licensed Materials and Services; and
  4. Information about Your use of Our customer services and support.

If We need to collect additional information or access certain parts of Your Device, We will first inform You and/or ask for Your consent (as applicable) and the Data will only be used in accordance with this Privacy Policy.

B. WHY WE COLLECT THE DATA AND BASIS FOR THE COLLECTION

We collect Your Data to:

  1. license the Licensed Materials or Services to You and to enable Us to provide You with the Licensed Materials and Services and any associated products or services
  2. provide You with software updates and support, improve and develop new products and services, and maintain and manage Our websites and other related services
  3. communicate with You about the Services
  4. fulfill Our legal and administrative obligations (such as making tax returns/payments)
  5. enforce this Privacy Policy and the Mobile Access License and User Agreement  
  6. 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 direct marketing purposes.

We base Our right to collect Your Data on the need of Your Data in order to provide You with the Licensed Material and Services, as stated above. To the extent that Your Data is used to improve and develop new products and services or to maintain and manage Our websites and other related services, We base Our use of Your Data on Our legitimate interest to perform such actions.

C. WHO MAY WE DISCLOSE DATA TO?

We may provide the Data We collect (set out under A above) to the Enterprise on behalf of which We provide You with the Licensed Material and Services.

We may also share the Data with other companies in the ASSA ABLOY group, as well as third party service providers to enable them to perform functions of the Services and to process Data on Our and/or the Enterprise’s behalf, in accordance with the purposes in Section B above.

To the extent that Your Data is disclosed or transferred to third parties as described above, for purposes not directly related to providing You with the Licensed Material or Services, We are responsible for ensuring such third parties’ use of Your Data in compliance with applicable data protection regulation and this privacy policy.

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); and
  • third parties, if so required to comply with mandatory law or requirements or to address fraud or technical issues.

D. 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 deleted or anonymised if:

  • the purpose of collection and use of Data has been achieved (as described above); 
  • the business for the Licensed Materials or Services concerned is discontinued (if earlier than achievement of the purpose as stated above); or
  • In relation to Data used only for purposes not directly related to providing the Licensed Material or Services to You (as further described under Section B above), if You request that Your Data is deleted by contacting Us (for contact information please see Section 6 below);

Anonymous information used purely for statistical purposes may be stored for a longer period than set out above.

1. 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 Union (the “EU”) and 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. When transferring Data to countries outside the EU/EEA, We use EU model clauses approved by the European Commission, in order to ensure an adequate level of data protection. You find the EU model clauses here

2. Precautions

We protect Your Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, You are responsible for protecting the Device against unauthorized access and use, and any transmission of Data will be at Your own risk.

3. Children

The Licensed Materials or Services are not directed to children under the age of 18, and We do not knowingly collect Data from children under 18.

4. Changes

We may amend this Privacy Policy from time to time. We will notify You before such change, through the Service.

5. Your rights in relation to Your Data

You have the right to access the information We hold about You and have any inaccuracies corrected. The accuracy of the information We hold about You is important to Us. You have a right to request a copy of Your Data being used by Us free of charge once a year.

You also have a right to request that the use of Your Data is restricted (e.g. if You believe that Your Data is not correct), that the use of Your Data ceases or that Your Data is deleted (e.g. in relation to Data used to develop new products or otherwise not directly connected to providing the Licensed Material or Services).

Please note that if You request that We cease to use Your Data or that it is deleted or restricted, We may not be able to provide You with the Licensed Material and Services.

You have a right to receive Your Data which is used in order to provide the Licensed Material and Services in a structured, commonly used and machine-readable format and You have the right to transfer such Data to another controller.

If You would like to exercise any of Your rights described above, please let Us know by emailing Us (for contact information please see Section 6 below). We will respond within a reasonable period of time upon verification of Your identity.

6. Contacts

As stated above, to the extent that We use Your Data to improve or develop new products and services, maintain and manage Our websites and other related services, ASSA ABLOY Mobile Services AB (Reg. No. 556909-5929) is the controller and responsible for ensuring compliance with applicable data protection regulation.

If You have any questions about how We use the Data or wish to exercise Your rights as described under Section 5 above, You can contact Us at mobilekeys@assaabloy.com or ASSA ABLOY Mobile Services AB, Box 70340, 107 23 Stockholm, Sweden.

If You have any questions about how the Enterprise uses the Data, please contact the Enterprise.

Version 1.2 dated 8 November 2016