ASSA ABLOY Privacy Policy

Last Updated:  February 28, 2024

SECTION 1 - GENERAL PRIVACY POLICY

SECTION 1 - GENERAL PRIVACY POLICY

This Privacy Policy applies to ASSA ABLOY Inc., an ASSA ABLOY Group company, and its U.S. brands, subsidiaries and affiliates located in the United States that link to this Privacy Policy (collectively "ASSA ABLOY”, "we", or “us”).  

This Privacy Policy describes the Personal Information that we collect about you through your use of ASSA ABLOY websites, products, services, programs, applications, online stores, and related transactions as described in the “How Does ASSA ABLOY Use Your Personal Information?” section below (together “ASSA ABLOY Services”).  

Your use of ASSA ABLOY Services signifies your acceptance of the Privacy Policy.

What Personal Information Does ASSA ABLOY Collect?

Through your use of ASSA ABLOY Services, we collect Personal Information from you, which is individually identifiable information about an individual consumer.  You may choose not to provide some Personal Information, however, we may not be able provide ASSA ABLOY Services, including processing orders, providing services, and completing transactions.  

We may collect the following types of Personal Information:

  • Information you voluntarily provide to us such as:
    • first and last name, title, address, email address, and phone number;
    • login account information to log into your account, send inquiries, feedback, or otherwise interact with us;
    • biometric information;
    • corporate and financial information; 
    • purchase history;
    • credit history information; and
    • any other identifier that permits the physical or online contacting of a specific individual.
  • Information collected automatically through your use of ASSA ABLOY Services such as:
    • Usage information:  such as the pages on the sites you access, the frequency of access and what you click on while on the sites;
    • Device information:  information about the device you are using, including hardware model, operating system, application version and browser;
    • Mobile device information:  when using ASSA ABLOY Services on your mobile device, information about whether you are using a mobile device or tablet, device type and carrier; and
    • Location information:  information such as IP addresses and geolocation information, location of your device or computer, version and time zone settings.
  • Information From Other Sources: We collect information from other sources, such as Shopify, Google, LinkedIn and Facebook, to help us update and analyze our records and to identify new customers.  If your Personal Information is shared to us by other sources, we advise you to check the privacy policy and cookies policy of any such sources before providing your information to them.

How Does ASSA ABLOY Use Your Personal Information?

ASSA ABLOY uses your Personal Information to provide ASSA ABLOY Services to you, to develop and improve ASSA ABLOY Services, for certain business-related purposes, and to protect legal rights – except as otherwise notified at the point of collection.  We may use your Personal Information for:

  • Account creation:  to set up an account, to provide customer support and training, and communicate with you about the use of ASSA ABLOY Services.
  • Sales orders and delivery of ASSA ABLOY Services:  to process orders for and deliver ASSA ABLOY Services, including communicating with you, processing payments, providing support and service for ASSA ABLOY Services, and sending promotional offers.
  • Improving ASSA ABLOY Services:  to analyze and improve the performance and effectiveness of ASSA ABLOY Services.
  • Product registration and warranty:  to register and track warranty information and communicate with you for registration and warranty purposes.
  • Communicate with you:  to communicate with you about ASSA ABLOY Services (e.g., by phone, email, chat).
  • Marketing purposes:  to send marketing communications about ASSA ABLOY Services and events, to respond to inquiries, and to display interest-based ads for ASSA ABLOY Services that might be of interest to you.  We do not use information that personally identifies you to display interest-based ads.  
  • Sweepstakes and contests:  to enter you into sweepstakes and contests if you choose to enter into sweepstakes and contests.
  • Surveys and polls:  to obtain information from you for market research purposes if you choose to participate in surveys and polls.
  • Fraud prevention:  to detect fraud and abuse to protect the security of ASSA ABLOY and its systems, including ASSA ABLOY Services, our customers and others.
  • Legal obligations:  to comply with legal obligations such as the prevention, detection, or investigation of a crime, to verify identity, to meet our internal and external audit requirements, for information security purposes, or as we believe to be necessary or appropriate to comply with applicable laws, and to respond to regulatory, law enforcement and other legal inquiries.

What Information Does ASSA ABLOY Collect and Process for Cookies?

We use cookies and other identifiers to enable our systems to recognize your browser and to provide and improve ASSA ABLOY Services.  You may limit the collection of cookies on our sites, however, you may not be able to fully use the available Services.  For more information about how cookies are handled, please read the Cookies Notice available on the individual ASSA ABLOY website with which you are interacting.

Does ASSA ABLOY Share Your Personal Information?

We share your Personal Information to global ASSA ABLOY affiliates and other third parties as described below that follow practices at least as protective as those described in this Privacy Policy.

  • Within the global ASSA ABLOY Group.  ASSA ABLOY is a global company with offices and locations around the world.  Functional and operational support may be provided by other ASSA ABLOY Group companies and your Personal Information may be shared within and processed by the global ASSA ABLOY Group companies to provide ASSA ABLOY Services, to fulfill orders, for account administration, to facilitate sales and marketing initiatives, for customer and technical support, and to promote business and product development.  The global ASSA ABLOY Group companies are not permitted to share or use your Personal Information for any purpose other than to provide services to ASSA ABLOY.
  • With Service Providers.  We engage service providers around the world and your Personal Information may be shared to them when necessary to fulfill the services they provide to us such as software, system, and platform support; direct marketing services; payment processing; cloud hosting services; advertising; data analytics; order fulfillment and delivery, and for compliance and audit purposes.  Our service providers are not permitted to share or use your Personal Information for any purpose other than to provide services to ASSA ABLOY.
  • With Independent Sales Agencies and Distribution Partners.  We have relationships with independent sales agencies and distribution partners to provide ASSA ABLOY Services to you, deliver ASSA ABLOY products to you and to fulfill orders.  The independent sales agencies and distribution partners are not allowed to share or use your Personal Information for any purpose other than to provide services to ASSA ABLOY.
  • With Third Parties for Legal Reasons.  We will share your Personal Information when we believe we are legally required to, such as:
    • under applicable law or legal process; 
    • to protect our rights, users, systems and ASSA ABLOY Services; 
    • as part of an investigation of unlawful conduct; to comply with requests from government agencies, including law enforcement and other public authorities, which may be outside your country of residence; and 
    • in the event of a change of business structure (e.g., merger, sale, restructure, acquisition).

How is Your Personal Information Secured?

We maintain physical, electronic, and procedural safeguards and features in connection with the collection, storage and disclosure of Personal Information.  In your use of ASSA ABLOY Services, we take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction.  ASSA ABLOY trains employees on its information security policies and guidelines and makes them available to its business partners as necessary.  In addition, ASSA ABLOY and its business partners enter into confidentiality agreements that require that (i) care and precautions be taken to prevent loss, misuse, or disclosure of Personal Information and (ii) any service providers only use Personal Information to perform services on behalf of ASSA ABLOY.

How Long Do We Keep Your Personal Information?

ASSA ABLOY retains Personal Information for a period of time determined by the type of Personal Information and the business purpose for retaining it, along with applicable legal requirements.  The retention periods also take into account the expectations and requirements of our customers, business partners, service providers, suppliers and others who share their Personal Information with us.  When we no longer need Personal Information, we securely delete or destroy it.

Opting Out of Marketing Emails

To opt out of marketing emails, you can use the unsubscribe link found in the email communication you received from us.  You may also use the “Contact Us” option within the relevant service to opt out and elect not to receive further emails from us.  Please provide the name of the ASSA ABLOY Service or email address from which you are receiving communications.

Targeted Advertising

We may use cookies and other technologies on our websites to collect information about your online activities over time and across different websites you visit in order to provide you with internet-based advertising.  You can generally opt out of receiving interest-based advertisements from members of the Network Advertising Initiatives or the Digital Advertising Alliances by visiting their opt-out pages.  When you opt out using those links, please note that you may still receive advertisements, although they will not be personalized based on your interests.

“Do Not Track” Signals

Some internet browsers incorporate a “do not track” feature that signals to websites you visit that you do not want to have your online activity tracked. We are unable to respond to Do Not Track requests at this time because our platforms are not currently configured to detect such signals.

Google Analytics

We may use Google Analytics to collect and process information about your use of ASSA ABLOY Services.  Google uses this information to provide reports to us so that we better understand and measure how users interact with ASSA ABLOY Services.  To learn more about how Google uses data, visit Google's Privacy Policy and Google’s page on "How Google uses data when you use our partners' sites or apps."  You may download the Google Analytics Opt-out Browser Add-On for each web browser you use, but this does not prevent the use of other analytics tools.  To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

Children’s Privacy

We do not provide ASSA ABLOY Services to children.  This website is not intended for anyone under the age of 18.  We do not knowingly collect Personal Information from children under the age of 16 without the consent of the child’s parent or guardian.

Changes to this Privacy Policy

ASSA ABLOY reserves the right to change or update this Privacy Policy at any time.  Revisions will be posted to this website along with the date the policy is posted and in effect.  When visiting our website, please be sure to review the Privacy Policy, which may have changed.  Your continued use of ASSA ABLOY Services after any posted revision indicates your consent to our use of your Personal Information in accordance with any revised and posted Privacy Policy.

How to Contact ASSA ABLOY:

If you have any questions or concerns about our privacy policy, or with the handling of your personal information, please contact our Privacy Officer at privacy.PNEA@assaabloy.com.

SECTION 2 - EU GENERAL DATA PROTECTION REGULATION (“GDPR”) DISCLOSURE

SECTION 2 - EU GENERAL DATA PROTECTION REGULATION (“GDPR”) DISCLOSURE

This disclosure applies to data subjects residing in the European Union (“EU”) or European Economic Area (“EEA”) Member States and is in addition to the information provided in Section 1 above.

Processing Personal Data

We may process your Personal Data based on your consent, for the performance of a contract or as necessary for the purposes of legitimate interests.  Processing for legitimate interests may include the following:

  • where the processing enables us to enhance, modify, personalize or otherwise improve our services/communications for the benefit of our customers;
  • to provide maintenance and support services;
  • to identify and prevent fraud;
  • to enhance the security of our network and information systems;
  • to better understand how people interact with our websites;
  • to provide postal communications which we think will be of interest to you; and
  • to determine the effectiveness of promotional campaigns and advertising.

You may object to any of the processing above, but this may affect our ability to carry out the tasks listed above for your benefit or to provide you with ASSA ABLOY Services.

International Transfers

Some of our computer systems are based outside of Europe, including in the United States, so we may transfer, access, or store your Personal Data outside of the EU, EEA, Switzerland, or another country that requires legal protections for international data transfers.  When we do, we ensure an adequate level of protection is provided for the information using one or more of the following approaches:

  • We may transfer Personal Information to countries that have privacy laws that have been recognized by the country from which the information is transferred as providing similar protections for the information (“adequacy”).
  • We may enter into written agreements, such as standard contractual clauses and other data transfer agreements, with recipients that require them to provide the same level of protection for the information.
  • We may seek your consent for transfer of your Personal Data for specific purposes.
  • We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.

Data Controllers and Data Processors

Under GDPR, there are two types of organizations that process Personal Data.  Organizations that determine the purpose and means of the processing of your Personal Data are called “Data Controllers.”  Organizations that carry out processing on behalf of a Data Controller are called “Data Processors.”  Only Data Controllers are obligated to comply with a Personal Data access request from a data subject.  It is important to note that ASSA ABLOY could either be a Data Controller or a Data Processor with respect to the processing of your Personal Data. 

Examples of ASSA ABLOY as the Data Controller:

  • You are a business contact at one of ASSA ABLOY’ partners or customers
  • You are a visitor to one of ASSA ABLOY’ websites

Examples of ASSA ABLOY as the Data Processor:

  • You are an employee of a customer using ASSA ABLOY Services
  • You are a user of an ASSA ABLOY Services purchased through one of our authorized distributors

Where ASSA ABLOY is the Data Processor, Personal Data inquiries should be submitted to the Data Controller.

Where ASSA ABLOY is the Data Controller, you can request to obtain:

  • confirmation that your Personal Data is being processed;
  • access to your Personal Data;
  • purpose of the Processing;
  • categories of Personal Data concerned;
  • the recipients or categories of recipients to whom your Personal Data has been or will be disclosed, in particular recipients in third countries or international organizations;
  • where possible, the period for which your Personal Data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from ASSA ABLOY rectification or erasure of your Personal Data or restriction of processing of your Personal Data or to object to such processing;
  • where the Personal Data is not collected from you, any available information as to their source; and
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the possible consequences of such processing for the data subject.

How Do I Make a Request?

If you believe ASSA ABLOY is the Data Controller of your Personal Data and you would like more information, please contact us as provided below and include the following information:

  • Personal Data Inquiry in the subject line;
  • Your full name, address and contact telephone number;
  • Any information used by ASSA ABLOY to identify or distinguish you from others of the same name (account numbers, unique ID’s, etc.); and
  • Details of the specific information you require, any relevant dates, and the action you wish ASSA ABLOY to perform with respect to your Personal Data.

The above Personal Data you provide is necessary in order to fulfill your request and for ASSA ABLOY to verify your identity and Personal Data we have about you.

Contact Information for ASSA ABLOY:

If you have any questions or concerns about our privacy policy, or with the handling of your personal information, please contact our Privacy Officer at privacy.PNEA@assaabloy.com.

Filing a Complaint

EU residents have the right to make a complaint to a data protection regulator in the event of dissatisfaction with how ASSA ABLOY manages their Personal Data or how inquiries are addressed or handled.  A list of European National Data Protection Authorities may be found here:  ARTICLE29 - National Data Protection Authorities (europa.eu).

SECTION 3 - U.S. STATE-SPECIFIC PRIVACY DISCLOSURE

SECTION 3 - U.S. STATE-SPECIFIC PRIVACY DISCLOSURE

Certain U.S. states provide you with rights to your Personal Information.  This disclosure is made in compliance with applicable U.S. state laws, supplements the information in Section 1 above, and applies solely to residents of California, Colorado, Connecticut, Utah, Virginia, Tennessee, Texas, Montana, Oregon, Indiana, Iowa and other U.S. states with similar data protection laws who utilize ASSA ABLOY Services (“Data Subjects”), as required by applicable laws.

Additional Information About the Collection and Processing of Your Personal Information

  • We do not sell your Personal Information.
  • We do not sell or share Personal Information of consumers under the age of 16.
  • We do not use or disclose Sensitive Personal Information for purposes other than listed below.

During the last 12 months, we collected and processed the following General Personal Information and Sensitive Personal Information:  

General Personal Information Collected

Source from which it is collected

Purpose for collection

Categories of Third Parties to whom it may be disclosed

Identifiers, such as name, postal address, email address, phone number, account information, customer number or other similar identifiers.

  • Consumers
  • Customers/Clients
  • Business Partners
  • Third-party companies such as service providers or website marketing partners
  • Provide ASSA ABLOY Services
  • Enhancing algorithms and analytics to improve ASSA ABLOY Services and enhance user experience.
  • Monitoring and maintaining the security and functionality of ASSA ABLOY Services and systems.
  • Communicating information to customers, clients and consumers such as newsletters, promotions, contests, account information, event registrations, contests and sweepstakes, and products/services information, including from our brands, subsidiaries and affiliates.
  • Service providers that verify identity and provide credit check information.
  • For compliance and legal obligations, and to exercise our legal rights.
  • Service providers such as website marketing partners and others that help transact ASSA ABLOY Services.
  • Business partners including independent sales agencies and distribution partners
  • ASSA ABLOY Group companies (global)
  • Advertising Networks such as technology partners that collect website usage details using cookies, web beacons and similar technology.

Internet or network activity information, such as browsing and search history; information about interactions with websites, applications or advertisements; cookies, beacons, pixel tags, mobile ad identifiers or similar technology; and IP addresses.

  • Consumers
  • Customers/Clients
  • Site users
  • Business Partners
  • Third-party companies such as service providers or website marketing partners
  • Provide ASSA ABLOY Services
  • Enhancing algorithms and analytics to improve ASSA ABLOY Services and enhance user experience.
  • Monitoring and maintaining the security and functionality of ASSA ABLOY Services and systems.
  • Communicating information to customers, clients and consumers such as newsletters, promotions, contests, account information, event registrations, contests and sweepstakes, and products/services information, including from our brands, subsidiaries and affiliates.
  • For compliance and legal obligations, and to exercise our legal rights.
  • Service providers such as website marketing partners and others that help transact ASSA ABLOY Services.
  • Business partners including independent sales agencies and distribution partners
  • ASSA ABLOY Group companies (global)
  • Advertising Networks such as technology partners that collect website usage details using cookies, web beacons and similar technology.

Inferences drawn from any of the Personal Information, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligences, abilities, and aptitude drawn from purchase or browsing history.

  • Consumers
  • Customers/Clients
  • Business Partners
  • Third-party companies such as service providers or website marketing partners
  • Provide ASSA ABLOY Services
  • Enhancing algorithms and analytics to improve ASSA ABLOY Services and enhance user experience.
  • Monitoring and maintaining the security and functionality of ASSA ABLOY Services and systems.
  • Communicating information to customers, clients and consumers such as newsletters, promotions, contests, account information, event registrations, contests and sweepstakes, and products/services information, including from our brands, subsidiaries and affiliates.
  • For compliance and legal obligations, and to exercise our legal rights.
  • Service providers such as website marketing partners and others that help transact ASSA ABLOY Services.
  • Business partners including independent sales agencies and distribution partners
  • ASSA ABLOY Group companies (global)
  • Advertising Networks such as technology partners that collect website usage details using cookies, web beacons and similar technology.

Commercial information, such as purchasing history (actual and potential), payment information, transaction history or purchasing or consuming histories or tendencies.

  • Consumers
  • Customers/Clients
  • Site users
  • Business Partners
  • Third-party companies such as service providers or website marketing partners
  • Provide ASSA ABLOY Services
  • Enhancing algorithms and analytics to improve ASSA ABLOY Services and enhance user experience.
  • Monitoring and maintaining the security and functionality of ASSA ABLOY Services and systems.
  • Communicating information to customers, clients and consumers such as newsletters, promotions, contests, account information, event registrations, contests and sweepstakes, and products/services information, including from our brands, subsidiaries and affiliates.
  • For compliance and legal obligations, and to exercise our legal rights.
  • Service providers such as website marketing partners and others that help transact ASSA ABLOY Services.
  • Business partners including independent sales agencies and distribution partners
  • ASSA ABLOY Group companies (global)
  • Advertising Networks such as technology partners that collect website usage details using cookies, web beacons and similar technology.

Sensitive Personal Information Collected

Source from which it is collected

Business or Commercial Purpose for collection (as defined above)

Categories of Third Parties to whom it may be disclosed

Geolocation data

  • Consumers
  • Customers/Clients
  • Site users
  • Provide ASSA ABLOY Services.
  • Service providers
  • ASSA ABLOY Group companies (global)

Biometric Information such as fingerprints, faceprints and voiceprints, iris or retina scans, or other physical patterns.

  • Consumers
  • Customers/Clients
  • Business Partners
  • Provide ASSA ABLOY Services.
  • Service providers
  • ASSA ABLOY Group companies (global)

Individual Rights Afforded by Some U.S. State Laws

Data Subjects may have the following rights regarding their Personal Information:

  1. Right to Know:  The right to know what Personal Information we process about you, including the categories of Personal Information collected, the categories of sources from which your Personal information is collected, the business or commercial purpose for collecting it, the third parties to whom we disclose your Personal Information, and the specific pieces of your Personal Information that we have collected.
  2. Right to Correct:  The right to request that we correct your Personal Information if you believe it is inaccurate.
  3. Right to Delete:  The right to request that we delete your Personal Information.
  4. Right to Not Receive Discriminatory Treatment:  The right to exercise your rights as described herein without any resulting discriminatory treatment, including retaliation.

Please note that these rights might be limited under the applicable data protection laws.  ASSA ABLOY remains the point of contact for your exercise of these rights.  Certain U.S. states allow for an appeal of a denied request; if your request is denied and the law of your state of residence allows for an appeal, we will provide you information on how to file an appeal.

Identity Verification

We cannot respond to requests or provide Personal Information if we are unable to verify your identity or your authority to make a request and confirm that the Personal Information relates to you.  Depending on the type, sensitivity, and value of the Personal Information, the risk of harm posed by any unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, whether the identity verification process is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated, the nature of the transaction between you and ASSA ABLOY, and available technology for verification, our verification process may include using existing authentication practices or matching two or three additional data points, and may also include submitting a declaration.  Personal Information provided for identity verification will only be used to verify your identity or authority to make the request.

How to exercise these rights

If you or your Authorized Agent wish to exercise any rights applicable to you as outlined in this U.S. State-Specific Privacy Disclosure, or if you have any questions concerning this Privacy Policy, you may:

If you have any questions or concerns about our privacy policy, or with the handling of your personal information, please contact our Privacy Officer at privacy.PNEA@assaabloy.com.

Requests must include sufficient information that allows us to reasonably verify that the requestor is the person about whom the Personal Information is collected and describe the request with sufficient detail that allows us to properly understand, evaluate and respond to it.  Please include:

  • Personal Data Inquiry in the subject line;
  • Your full name, address and contact telephone number;
  • Any information used by ASSA ABLOY to identify or distinguish you from others of the same name (account numbers, unique ID’s, etc.); and
  • Details of the specific information you require, any relevant dates, and the action you wish ASSA ABLOY to perform with respect to your Personal Information.

The above Personal Information you provide is necessary in order to fulfill your request and for ASSA ABLOY to verify your identity and Personal Information we have about you.  If using an Authorized agent, and depending on the nature of the request, we may require proof that you gave the agent signed permission to submit the request.  We may require you to directly verify your identity and confirm that you have provided the agent with permission to submit the request.

In case of complaints, you have the right to lodge a complaint with the competent supervisory authority, for example, the Attorney General in your state of residence.