This policy applies to AADG, Inc. owned or operated websites. 

We will collect and process the personal data you provide through our websites.

What personal data will ASSA ABLOY process, and why?

ASSA ABLOY will process your personal data in accordance with the following description. 

• To provide the services you sign up for.
• To send marketing communications when we have your permission, or when permitted by law.
• To personalize our services (for example, so you can sign in)
• The data we process and collect will principally come from your use of the application required to use the “service.”

A. ASSA ABLOY will process the personal data set out in this section A to fulfill the contract  and to provide the service to you: \
i. Name, Email address, Mailing address, location data, and other data collected.
ii. Store access usage and store access visitors, including the type of device or browsing you are using.

B. ASSA ABLOY will process the personal data to achieve our legitimate interest in developing and updating our products and services:
i. Information related to the usage and technical data relating to your device.

C. ASSA ABLOY does not sell or rent your personal data to third parties 

“Do Not Sell My Personal Information”

Our Legitimate interest for collection and processing of personal data

We will use your personal data always with a lawful basis when:

• It is necessary for the “Performance of a Contract”(e.g., fulfill a sales order)
• You provide “Consent” the use of it (e.g., subscribed your email to the marketing list)
• It is in our “Legitimate interest” (e.g., share your data with other ASSA ABLOY relevant entities)
• We are “Legally Obligated” (e.g., to fulfill legal and statutory requirements)

To justify the processing under section B above, ASSA ABLOY has performed a balancing test to ensure that your privacy interests do not outweigh our legitimate interest. Since the processing is limited to non-sensitive data and processed data is aggregated, we have concluded that your privacy interest does not outweigh our legitimate interest. As a data subject, you have a right to obtain information on how we conclude the balancing test in your case.

Transfer of personal data

We may transfer your personal data to the following categories of recipients to the extent necessary to complete the processes stipulated above or if legally required:  

• Government agencies and institutions;
• Other legal entities within the ASSA ABLOY group; and
• Our service providers, such as legal counsel or IT hosting providers relevant to the “service.” 

These third parties may only use your personal data according to our instructions.

International Use

We exercise care in facilitating the transfer of data between your computer or device and our computers or servers (or third party servers which operate and store personal data for the “service”). We have the mechanisms in place to safeguard your personal data after we receive it.

We have our servers and offices in the European Union and the United States; it is possible that during one of our processes, your personal data may be transferred to, stored, or processed in one of these locations. As the data protection, privacy, and other laws of the United States might not be as comprehensive as those in the EU, we take many steps to protect your privacy, we could offer a Data Processing Agreement for EU customers. Please request this through our communication methods described at the end of this notice.

When you use the “service,” you understand and consent to the collection, storage, processing, and transfer of your personal data to our facilities in the European Union, the United States and, the third parties with whom we share it as described in this notice.

For how long will ASSA ABLOY store your personal data?

ASSA ABLOY stores the personal data as long as it is necessary to fulfill the purpose for which the data has been collected, unless we may, or are obligated by law to store personal data for a longer time. ASSA ABLOY will delete your data when we are no longer required by law to retain it or when it is no longer necessary for the purposes of providing the “service.” Upon termination of the “service,” the data will be deleted after three (3) months of such termination. 

Right to access and rectification

You have the right to request access to the personal data relating to you. This includes the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing. You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete. As soon as we become aware of any inaccurate personal data being processed, we will always correct such personal data as soon as possible and notify you accordingly.

Right to erasure

You may request that your personal data be erased for example in the following situations: 

•  
• If the personal data is no longer necessary for the purposes for which it was collected;  
• if you object to the processing of personal data where we do not have an overriding legitimate interest; 
• if the processing is unlawful; or 
• if the personal data has to be erased to enable us to comply with a legal requirement. 

If you have any questions about your right to erasure, please contact the ASSA ABLOY Divisional DPM (Data Protection Manager). Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground. 

To request removal, you need to provide specific information that you want to remove, such as the URL for each page where the personal data is located, so that we can find it. We are not required to remove any content, or personal data that: (1) federal or state law requires a third party or us to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or personal data. The removal of your personal data from the “service” does not ensure complete removal of that personal data from our systems or the systems of our service providers.

Right to object 

You are entitled to object to our use of your personal data that we base on our legitimate interest. If you object, we will no longer process your personal data unless we can show that we have compelling legitimate grounds for the processing that overrides your interests or rights and freedoms or if we need it to establish, exercise, or defend legal claims.

Right to restriction

You can request us to restrict the processing of your personal data in the following situations:  

• If the processing is no longer necessary for the purposes for which it was collected or otherwise processed; 
• if you withdraw your consent for the use of data that we base on your consent;  
• if you believe the personal data may not be correct; 
• if you believe that the processing is unlawful; or 
• if we process your personal data based on our legitimate interest, where we do not have an overriding interest in relation to your privacy interest. 

Right to Data Portability

If you request access to personal data about you that you have provided and if the personal data is being processed automatically, you may request that the data is provided in a structured, commonly used and machine-readable format and you may also request that the personal data is transferred to another business if this is technically possible.

Tracking of usage statistics

The “websites” makes use of Google Analytics, an analysis service provided by Google. 

With our “websites” we could collect some information automatically using various mechanisms, including but not limited to cookies and pixels. This collection may include but is not limited to the personal data described on “What personal data will ASSA ABLOY process and why?” section. We collect this (non-identifying information) to help diagnose problems, to administer the “service,” to help identify you and to gather broad demographic information. 

A “cookie” is a text file that stores on a computer for record-keeping purposes. You can find how we use cookies in our cookies policy. You may set your browser to attempt to reject cookies, and you may be able to use the “service.” Please note that some features of the “service” may not be available if your browser does not accept cookies. 

“Pixels” are small graphics with unique identifiers, which use is to track movements of web users. Different than cookies, pixels are small graphics that could be the size of the period at the end of the sentence, which are embedded invisibly on web pages. It is possible that our third-party analytics providers may place pixels on the Site that track other websites you visit, before and after your visit. Our third-party analytics providers may use information obtained from pixels. ASSA ABLOY does not control the use of pixels by third parties.

As we track website usage information as described above, your selection of the DO NOT TRACK option in your browser may not affect our collection of data. The only way we know to completely “opt-out” of the collection of information through cookies or other tracking technologies is to delete and disable cookies and other tracking/recording tools. 

Some of our websites may contain links to third-party websites, including social media such as Facebook, LinkedIn, or Twitter. We are not responsible for the privacy practices or content of any of these linked sites. Linked sites may collect personal data from you that is not subject to our control. The personal data collection practices of Linked Sites will be governed by that site’s privacy policy.

We take measures to protect all personal data transferred to a third party, or other countries, in accordance with applicable data protection laws and, as stated above. No transmission of data over the Internet can be 100% secure. There is always a risk that information collected by and displayed on the “service” may be compromised or accessed, notwithstanding the steps we take to secure your personal data. For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the “service” may abuse or misuse your personal data. Accordingly, you agree that you are providing such personal data at your own risk.

Children’s Privacy

The “service” is Not for or Directed to Children nor anyone under 18 years old, we do not intend to and will not knowingly collect any personal data from children under the stated age. If we learn that we have collected personal data from an under age of 18, we will remove that personal data immediately and delete it from our servers (if not required or resulted by applicable law and this Privacy Notice). If you believe content from an under 18 years has been posted in our “service,” please notify us by contacting us at  Privacy.Americas@assaabloy.com 

California Rights

California Minors. The “service” is not intended for anyone under the age of 18. If you qualify as California resident, under 18 years old and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at Privacy.Americas@assaabloy.com

California Civil Code Section 1798.83 allows California residents who have used our “service” to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal data (if any) for direct marketing purposes in the preceding calendar year. If you qualify and which to request this personal data, make a request to Privacy Americas with “California Privacy Rights” as the title of your letter, please mail it to 110 Sargent DR, New Haven CT. 06518.

Our obligations under California law are satisfied as long as we anonymize the personal data or render it invisible to other users and the public; therefore, we are not required to delete the information posted by you.

Changes and Updates 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 take appropriate and feasible steps to 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 “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.”

We will make good faith efforts to resolve any requests to correct inaccurate personal data except where (1) the request is unreasonable, (2) requires disproportionate technical effort or expense, (3) jeopardizes the privacy of others, or would be impractical. We will comply with the specific time required in the applicable law to address your concerns, free of charge if possible for the business and the allow number of times, under applicable law guidance. 

Contact Information and Questions

AADG, Inc. is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to “Attn.: ASSA ABLOY AMERICAS Data Protection Manager” at ASSA ABLOY AMERICAS 110 Sargent DR. New Haven, CT. 06511 or Privacy.Americas@assaabloy.com