Privacy Notice

ASSA ABLOY (“we,” “us”) is committed to protecting your Personal Information. In connection with your use of this ASSA ABLOY service. The purpose of this Privacy Notice is to describe how we collect and process the Personal Information that we receive in connection with your use of the website or app, which will be referred to as “service” in this notice.

This policy applies to Hanchett Entry Systems, Inc. owned or operated websites and mobile apps.

We will collect and process the Personal Information you provide through our websites and apps.

What Personal Information will ASSA ABLOY process, and why?

ASSA ABLOY will process the following personal information in accordance with the following description set out in this section A to fulfill the service to you:

Responding to your request and support

When you request information from us: your company profile, your name, title, and contact information, which may include address, country information, email and/or telephone number which you submit to obtain information from us and the products or services you would like to learn about;
When you provide your consent to send you marketing information or other information requested;
When you create an account to order from us: your company profile, your name, title, and contact information, which may include address, email and/or telephone number and delivery details as well as any other information required to verify and fulfill the order and order history; we may use this personal information to meet our legal and compliance requirements
When using our applications, which may include administration of one of our products unless otherwise noted: your company profile, your name, title, and contact information, which may include address, email and/or telephone number, username and password, and other information relevant to using the application in question;
When you provide your consent and use our mobile access applications, we will collect your email address, property reservation information, and account information, electronic key, including username and password;
To provide customer support on the products and services we provide, we will need to collect contact information, which may include your customer number or property name, and information about the issues experienced;

Surveys and Training

When completing a survey, your contact information and opinions and impressions of our services and products, unless an anonymous survey request. If anonymous, your responses will not be saved with your profile.
When enrolling for training and completing training: your company profile, your name, title, and contact information, which may include address, email and/or telephone number, and all related transcript information including classes attended, completion rate, etc.

Websites, Applications, and Services

When you visit and use our websites, services, applications, or accept additional information: we collect your statistical and anonymous information from your browsing behavior and anonymous cookies. This includes referral information, your device and browser information, preferred language, pages visited, time spent on each page, links clicked to provide and improve our services.
When you visit our websites and accept the use of cookies; we collect IP information to derive geolocation information, i.e., city area; which links you choose to click, user preferences, i.e., what users do and do not like on our website and device identifiers, and this enables us to improve our service with user feedback further. This information is stored in pseudonymized user profiles for statistical reasons, which neither our service providers nor we use to identify individual users.
When you agree to the use of re-marketing, tracking cookies/technologies, our ads may appear when you visit other websites or platforms. For example, we may use Google Ads “remarketing” service to serve ads to you based on your prior use of our website. Remarketing displays relevant ads tailored to you based on what parts of our website you have viewed by placing a cookie on your device. The cookie is used to indicate, "This person visited this page, so show them ads relating to that page. We also collect information about our ad campaigns to understand how many times an ad has been shown to each user and how many times users have clicked on it. Our third party providers can further associate the above information with your consent with your advertising profile and preferences that includes your advertising ID such as Android Advertising ID (AAID) and Apple’s Identifier for Advertisers (IDFA).
If you do not wish to participate in our Google Ad remarketing, you can opt-out by visiting Google's Ads Preferences Manager. You can also opt-out of third-party vendor's use of cookies by visiting this (NAI Consumer Opt Out (networkadvertising.org).
When interacting with us on social media, including Facebook, YouTube, LinkedIn, Twitter, and Google+: We may collect your company profiles, contact information, other related information, and basic details from your social network profile. These details we receive may depend on your social network account privacy settings; however, they might include the above and additional available details.

Information we collect from third parties

We may receive your Personal Information (including contact information) from your employer for purposes further defined below.
We receive Personal Information when you use our customer's and partners' services, such as installation services, sales partners, etc.
We may also receive information about you from other ASSA ABLOY group companies, services, or products that you interact with.
We may acquire information from third parties that includes information regarding projects in our business area and key project individuals. This information includes the name, role, and business contact details. When this occurs, we will notify you using the contact details available and provide the opportunity to object to using your information to provide legitimate business communications regarding our products and services.
We may use information collected from other sources (e.g., Shopify, Google, Facebook) to update and analyze our records to identify new customers. Note: we have no control over how your information is processed (collection, store, or use) by other applications; we advise you to check the privacy policies and cookies policy of any such websites before providing any information. ASSA ABLOY will process your Personal Information for providing you with the service and support connected with the “service.”

How and Why ASSA ABLOY will use your information depending on the service your use.

Why do we process this Personal Information?	What is the legal basis for such processing?
To authorize access to our services.	When requesting a service like setting up an account, training, using mobile services or our applications, or accessing customer support, certain Personal Information is necessary to ensure we can get in contact with you and provide what is requested. We also want to ensure you have a chance to review and accept any applicable terms and conditions.
To provide you with the information you request.	Using your Personal Information in this way is necessary for us to respond to your request.
To manage your account, for example, by sending you password reminders or notifications of changes to your account details.	Using your Personal Information in this way is necessary to provide you with an online account and respond to your request.
To fulfill your order where you have purchased from one of our websites, to contact you about sales and as a part of our customer relation and support procedures.	Using your Personal Information in this way is necessary to perform our contractual obligations where you have placed an order on this website.
To provide recommendations for shoppers on our eStore.	As described in this notice. Collect behavioral information of shoppers, such as which products the shoppers search, view, add to cart, and more. This information may be used to provide recommendations.
To carry out statistical analysis about the use of the website and our services to better understand how they are used and improve.	As described in this notice. To look at this information to understand how our website is being used to manage and improve it. Since no sensitive Personal Information will be processed and the processing is limited, we have concluded that the improvements and analysis take precedence over your privacy interest.
To comply with legal requirements to which we are subject, such as tax, legal, financial, and compliance reporting requirements.	Using your Personal Information in this way is necessary for us to comply with our legal, tax, financial, and reporting compliance obligations.
To better understand your interests and preferences, provide you with an experience tailored to those interests and preferences.	As described in this notice. To look at the preferences that we derive from your browsing behavior to personalize content and better meet your needs as a customer, provided this be in line with your marketing choices.
To better understand your wishes, expectations, and requirements to develop our activities, products and services, offerings, customer service, and communications.	As described in this notice. To look at the feedback that we derive from your survey responses to enable good customer service and support, deal with your questions, correct erroneous information, or dispatch information that you have requested. If we want to identify a person in a survey, this is only done if expressly stated in the survey's invitation.
To statistically analyze your feedback from surveys over time to develop and improve our activities, products and services, offerings, customer service, and communications to you.	As described in this notice. To analyze customers' behavior and patterns through the survey responses over time to give you recommendations and adapted services based on the interests of others with similar behavior patterns. The survey may be sent to you again, and we would then want to compare results from the previous occasion to verify that we are improving.
To personalize and measure the effectiveness of advertising on our website and third party websites.	We use third-party vendors re-marketing cookies, such as Adroll and Google Ads, to serve relevant advertisements on our marketing partners' display network with your consent.
To further understand users’ needs, optimize services, enhance their experience, and improve our services.	With your consent, we enable cookies that allow us to understand your experience better and, with your express consent, may link this information for further understanding.
According to your marketing preferences, to send you communications about relevant solutions, products, and services, including updates that may be of interest.	We will only send you marketing materials where we have your consent, a contractual basis, or where is a process mentioned in this notice to keep you updated.
If you submit a question or a request on a social media platform to interact with you as requested.	As described in this notice. To use the Personal Information you share with us from these sources to provide the information requested, improve the quality of our products and services, and engage in the conversations on those platforms. We will NOT use these mediums to provide unsolicited direct marketing.
Invite customers to register for our services, i.e., support, eStore, or end-users, to create a mobile key.	As described in this notice. To invite customers to register for our services. Should the customer fail to activate their account or complete registration, we will remove their account from our services.
To support our customers, we sometimes need to simulate and troubleshoot an issue using a copy of their database from our products and services.	As described in this notice. To provide support and with the customer’s permission, obtain a copy of the local database. This database contains Personal Information from our customers but also their customers. Once the issue is resolved, Personal Information is deleted.
To process pseudonymized information from customer databases for test purposes, investigate usage patterns, perform simulations to improve our products and services.	As described in this notice. To improve test scenarios for our products and services, improve quality, identify improvements from usage patterns, and shorten lead-time to market that ultimately benefits our customers as well.

C. ASSA ABLOY does not sell or rent your Personal Information to third parties Do Not Sell My Personal Information

Transfer of Personal Information

We may transfer your Personal Information 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 Information according to our instructions.

International Use

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

We have our servers and offices in the European Union and the United States; it is possible that your Personal Information may be transferred to, stored, or processed in one of these locations during one of our processes. 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 Information 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 Information?

ASSA ABLOY stores the Personal Information as long as it is necessary to fulfill the purpose for which the information has been collected unless we may or are obligated by law to store Personal Information for a longer time. ASSA ABLOY will delete your information 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,” or when the required retention period has expired. The following is a list of retention periods for Personal Information relevant to this Privacy Notice.

Type of information stored	How long is it stored?
Contact information you provide us in forms submission, contact request, and events such as; Your name, email address, region/country, and company name.	Deleted 24 months after becoming inactive or after three email bounces.
Your responses in surveys that you participate in.	Deleted 24 months after the end of the survey period. Aggregate information that cannot be tied to an individual may be stored longer.
Marketing preferences such as opt-in or opt-out to receive information and newsletters through email.	Deleted 24 months after becoming inactive or after three email bounces.
Information related to our business relationships, such as information in orders and quotes, requirements you provide, and delivery information.	During our business relationship and seven years thereafter. Information may be stored longer when we are legally required to do so.
Application information is collected from users of our mobile applications.	Deleted after 24 months for active users or after becoming inactive
Customer database copies related to support cases.	Deleted within six months after the support case is resolved.

Your rights

Right to know personal information collected

You have the right to know which personal information has been collected from you.

Right to say no to the sale of personal information

ASSA ABLOY does not sell your personal information. ASSA ABLOY could share your personal information with service providers and with other ASSA ABLOY entities only for “necessary” purposes, according to this notice. You have the right to know which personal information is disclosed and to who. The service providers and other ASSA ABLOY entities perform processes on behalf of ASSA ABLOY. Neither the service provider nor other ASSA ABLOY entities sells personal information.

Right to access and rectification

You have the right to request access to the personal information relating to you. This includes the right to be informed whether or not personal information about you is being processed, what personal information is being processed, and the purpose of the processing.

Right to deletion

You may request that your personal information be deleted, for example, in the following situations:

If the personal information is no longer necessary for the purposes for which it was collected;
If you object to the processing of personal information where we do not necessarily need it to maintain it;
If the processing is unlawful; or
If the personal information has to be deleted to enable us to comply with a legal requirement.

Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground. We are not required to delete personal information 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 the deletion or (5) you received compensation or other consideration for providing the Content or personal information. The deletion of your personal information does not ensure the complete removal of that personal information from our systems or the systems of our service providers.

Right to obtain equal service, even if they exercise their privacy rights.

ASSA ABLOY does not discriminate against any employee who exercises the rights mentioned. You are entitled to exercise your rights without prejudice to receive different services in quantity or quality.

Tracking of usage statistics

The “websites” and “Apps” makes use of Google Analytics, an analysis service provided by Google, to help us track usage statistics about visitors to our website or app on an aggregated level.

Google Analytics collects information such as how often users visit the website or app and their geographical location. ASSA ABLOY uses the information to improve the website or app’s technical performance, to optimize the performance of the website or app’s features, to improve users’ experience of the website or app, to better tailor the website or app to users’ interests and needs and to make the website or app easier to use.

Google’s possibility of using and sharing information collected by Google Analytics about your visits to our mobile application is restricted by the Google Analytics Terms of Service (Terms of Service | Google Analytics – Google). For information about how Google uses your Information when you use the website or app, visit How Google uses information from sites or apps that use our services – Privacy & Terms – Google.

By installing the website or app, you consent to Google Analytics’ collection and processing of your Information. For information about how to withdraw your consent, visit https://tools.google.com/dlpage/gaoptout

With our “websites” and “apps,” 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 Information described on the “What Personal Information will ASSA ABLOY process and why?” section. We collect this (non-identifying information) to help diagnose problems, administer the “service,” to help identify you, and 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 “service” features may not be available if your browser does not accept cookies.

“Pixels” are small graphics with unique identifiers, which use to track web users' movements. Different from 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. 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 and apps usage information as described above, your selection of the DO NOT TRACK option in your browser may not affect our collection of information. 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 and apps 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 websites. Linked sites may collect Personal Information from you that is not subject to our control. That site’s privacy policy will govern the Personal Information collection practices of linked websites.

We take measures to protect all Personal Information transferred to a third party, or other countries, in accordance with applicable data protection laws and, as stated above. No transmission of information 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 Information. 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 Information. Accordingly, you agree that you are providing such Personal Information 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 Information from children under the stated age. Suppose we learn that we have collected Personal Information from an under the age of 18. In that case, we will remove that Personal Information 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 a 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 Information (if any) for direct marketing purposes in the preceding calendar year. If you qualify and request this Personal Information, make a request to Privacy Americas with “California Privacy Rights” as your letter's title; please mail it to 110 Sargent DR, New Haven CT. 06518.

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 Information 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 relevant law guidance.

Contact Information and Questions

Hanchett Entry Systems, Inc. is responsible for the processing of your Personal Information, 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