PRIVACY POLICY FOR Aptus Home APPLICATION

BACKGROUND

This Privacy policy forms a part of the Aptus Home User Agreement and is part of the agreement between You and ASSA ABLOY Opening Solutions (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 Aptus Home 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 so that We can provide You with the Licensed Materials and Services. This Privacy policy describes the information We collect (“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.

WHAT THIS PRIVACY POLICY COVERS

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.

This privacy policy describes how We use Your Data.

THE DATA WE MAY COLLECT

Once You have downloaded the Aptus Home App, no personal data is collected when using it.

We may collect the following Data:

Technical data and related information about the Device being used for the Services, including unique push ID, operating system, application software and peripherals;

Information related to the use and performance of the Licensed Materials and Services;

WHY WE COLLECT THE DATA AND BASIS FOR THE COLLECTION

We collect Your Data to:

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;

provide You with software updates and support, improve and develop new products and services, and maintain and manage Our websites and other related services;

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.

WHO MAY WE DISCLOSE DATA TO?

We may provide the Data We collect (set out under THE DATA WE MAY COLLECT) to 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 behalf, in accordance with the purposes in Section WHY WE COLLECT THE DATA AND BASIS FOR THE COLLECTION 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:

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.

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 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 THE DATA WE MAY COLLECT, above), if You request that Your Data is deleted by contacting Us (for contact information please see Section INFORMATION RIGHTS, below).

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

TRANSFER

We may share the information we collect 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.

As described above, no personal data is collected when using the  Aptus Home app.

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.

CHILDREN

The Licensed Materials or Services are not directed to children under the age of 13, and We do not knowingly collect Data from children under 13.

CHANGES

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

Version 1.00 July 5, 2021