Privacy policy for mobile access application

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 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 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 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

The mobile access application provided to You is used together with a platform provided by HID Global Corporation, a company within the ASSA ABLOY Group. We provide You with the Licensed Material and Services on behalf of HID Global Corporation. Therefore, you should also bear in mind that, as Your use of the Licensed Materials and Services has been requested by HID Global Corporation, HID Global Corporation may also receive and use some or all of the Data, either directly from You or from Our systems.

HID Global Corporation 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 HID Global Corporation collects and/or uses about You, or how and why HID Global Corporation collects and/or uses the Data. HID Global Corporation 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 HID Global Corporation.

This privacy policy describes how We use Your Data both on behalf of HID Global Corporation and for Our own use.

The data we and/or hid global corporation may collect

Once You have received the credentials in the mobile access application, no personal data is collected when using it.

We and/or HID Global Corporation 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; and

Geo location services

We use Location Services to improve performance in reader detection. Location services is used to wake the app in Background so that it can communicate with locks and readers over Bluetooth or GPS.

Geo location data is only used within the mobile app and not transferred anywhere. No personal data is used in conjunction with the Geo location service.

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 AND/OR HID GLOBAL CORPORATION MAY COLLECT) to HID Global Corporation 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 HID Global Corporation’s 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 AND/OR HID GLOBAL CORPORATION 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 Mobile Access 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 2.45 March 23, 2021