Legal

Privacy Policy
Cookies Policy

The Company

This Privacy Policy applies to ASSA ABLOY Singapore Pte Ltd ACRA/RCS Registration no. 199606073E (referred to as us, we, our or the Company).

Any person, firm, company, government body or other entity who provides personal information to us or accesses or uses our websites at assaabloyopening solution.com.sg or our websites of our brands (including ABLOY, APERIO, LOCKWOOD, PYROPANEL, TRAKA, WHITCO and YALE) (our websites) is referred to as you or your.
Customer Privacy

Customer’s privacy is seriously taken by us and we will only collect, record, hold, store, disclose, transfer and use your personal information as outlined below.

We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected. Data protection is a matter of trust and your privacy is important to us. We shall therefore only use your name and other information, which relates to you in the manner set out in this Privacy Policy. We will only collect information where it is necessary for us to do so and we will only collect information if it is relevant to our dealings with you.

You can visit the Platform (as defined in the Terms of Use) and browse without having to provide personal details. During your visit to the Platform you remain anonymous and at no time can we identify you unless you have an account on the Platform and log on with your username and password. We are committed to complying with the Personal Data Protection Act 2012. If you have any comments, suggestions or complaints, please contact us (and our Data Protection Officer) through our contact us page.
Collection, Holding, Use and Disclosure of personal information

We only collect personal information that is reasonably necessary for our functions and activities or our dealings with you.
1. How we collect personal information
  
  We collect personal information in a number of ways, including directly from you, such as when you submit a request, send us an email, place an order, complete a survey or register for a promotion, when you download and use an app relating to one of our products or services, or from other sources such as website analytics or how and when you use our products and services, including technical information.
  
  For example, if you place an order with us, you will be asked to provide such information as is reasonably necessary for us to consider your order and (if accepted) transact the order with you. Without such information we would be unable to consider your order and (if accepted) transact your order. We may also collect personal information from third parties, including credit reporting bodies and our service providers who are engaged by us to provide goods and services to you.
2. The kind of personal information we collect
  
  The personal information we collect and hold may include information such as your name, address, email address, telephone number financial and credit information and information relating to your use of our products and services, including your user ID and password, video, video and photo images, voice recordings, and usage related to such products and services including location data and device-specific information.
3. How we hold your personal information
  
  We may hold personal information in a number of formats and in various types (both physical and electronic) of storage facilities (including the Cloud) that may be owned by us or our third party service providers.
4. How we use your personal information
  
  We collect, hold, use and disclose personal information for a number of purposes including: our dealings with you, for the provision of products and services, as part of our customer care procedures, to manage or improve our websites and for statistical analysis.
  
  For example, we may disclose personal information to our delivery service providers in order to deliver purchased products, to our payment service providers in order to process payments through our websites and to our IT service providers in order to host, develop and provide support sites. We may also use and disclose personal information:
  - for direct marketing or remarketing, including sending you news, invitations, information about our activities and general promotional materials;
  - to maintain our relationship with you;
  - to credit reporting bodies;
  - for purposes related to the Company’s research, development and analysis, planning, web site development, security and risk management;
  - where a third party acquires or wishes to acquire an interest in the Company or the business of the Company; or
  - to the extent we are required or authorised by law to do so.
  If you do not wish to receive direct marketing communications from us, please contact the Company’s Privacy Officer on the contact details listed below.
5. Who we disclose your personal information to
  
  As part of the above collection, holding and use, we may disclose personal information to third parties, including our other ASSA ABLOY group companies, service providers, business partners and licensees in both Singapore and overseas (including in the United States and Europe, as well as outside the European Economic Area).
  
  We only disclose personal information to third parties to the extent necessary for them to provide the particular goods and services for which they are engaged to provide or as otherwise set out in this Privacy Policy.
  
  Where personal information is disclosed to third parties outside Hong Kong, those third parties may be required to comply with acts and practices required by applicable laws of an overseas country.
  
  By providing us your personal information you acknowledge, agree and consent to our use and disclosure of your personal information in the manner set out in this Privacy Policy, including to overseas recipients.
  
  You also warrant that you are authorised to provide such information and that the information is, to the best of your knowledge, current and accurate.
  
  The provision of your personal information is voluntary. However, if some of your personal information is unable to be collected by us, we may not be able to continue our dealings with you, including providing you with products or services.
  
  Other than as set out in this Privacy Policy, we do not sell or otherwise provide your personal information to third parties or make any other use of your personal information which is not incidental to your relationship with us.
  
  Our websites may also contain links to other websites. Those links are provided for convenience only, and we are not responsible for the privacy practices or the content of those other websites. The use of such websites is at your own risk in all things.
  
  Our websites may interface with social networks to allow users access to various social platforms (Facebook, YouTube, Twitter, LinkedIn, etc.). To understand how and what information is collected and what cookies are used by such third parties, you should check their privacy policies.
Withdrawal of Consent

You may communicate your objection to our continual use and/or disclosure of your personal information for any of the purposes and in the manner as stated above at any time by contacting us at our e-mail address below.

Please note that if you communicate your objection to our use and/or disclosure of your personal information for the purposes and in the manner as stated above, depending on the nature of your objection, we may not be in a position to continue to provide our products or services to you or perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event.
Updating Your Personal Information

You can update your personal information anytime by accessing your account on our Platform. If you do not have an account with us, you can do so by contacting us at our e-mail address above.

We take steps to share the updates to your personal information with third parties and our affiliates with whom we have shared your personal information if your personal information is still necessary for the above stated purposes.
Accessing Your Personal Information

If you would like to view the personal information we have on you or inquire about the ways in which your personal information has been or may have been used or disclosed by us within the past year, please contact us at our e-mail address below. We reserve the right to charge a reasonable administrative fee for retrieving your personal information records.

If you have an account with us, you may access details of your order by logging into your account on the Platform. Here you can view the details of your orders that have been completed, those which are open and those which are shortly to be dispatched and administer your address details, bank details and any newsletter to which you may have subscribed. You undertake to treat your username, password and order details confidentially and not make it available to unauthorised third parties. We cannot assume any liability for misuse of your username, password or order details, except as stated in the Terms of Use.
Cookies

We and our service providers may utilise various technologies (including cookies (generally), analytic cookies, targeting, advertising or remarketing cookies, web beacons and pixels, and other types of technologies) (collectively cookies) which assist us in our functions and activities including our dealings with you, for the provision of goods and services and for marketing and remarketing purposes. For example, cookies allow us to monitor traffic patterns and usage statistics, and to identify visitors.

A "cookie" is an electronic information file that is stored and accessed on your computer or device. There are several types of cookies used on our websites which may remain on your computer or device for varying periods of time, including in some instances, permanently, unless you delete them from your computer or device. We may also use cookies in other platforms, including in our emails, newsletters and other electronic communications.

We also use third party service providers, including Google Analytics, Usabilla and Hotjar, to collect and process data and to analyse our visitors' behavior on an anonymous and aggregate level. This allows us to log information about visits and site visitors for various purposes, including remarketing purposes and in order to improve the user experience of our websites.

To assist in our functions and activities, cookies are also used in our remarketing practices in various instances, including in order to determine who has previously visited or interacted with our websites, used our mobile apps or interacted with our videos. This allows us to advertise online to you through third parties, including Google, who may also use cookies in order to track website activity and show our advertising online across various websites, platforms and devices.

You can opt out of Google Analytics and Google’s use of cookies by searching ‘Google opt out’.

If you do not wish to accept cookies, you should set your computer or other device to not automatically accept cookies from being stored or to inform you whenever a site requests storing a cookie. Previously stored cookies may also be able to be deleted from your computer. However, be aware that some areas or functions of our websites depend on cookies and may not work if you delete or do not accept them.

Please contact us at Cookies.Au@assaabloy.com for more information about the use of cookies.
Security

Once we hold any personal information, we will take reasonable steps to protect that information from unauthorised access, loss, misuse, modification, interference or disclosure. Where your personal information is provided to us electronically (including over the internet or via the use of any apps) we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

If we collect any unsolicited personal information or if we no longer need the information for our activities or functions, we will, if practicable and reasonable to do so, destroy the information or ensure that the information is de-identified.
Access to and correction of personal information

If you wish to request access to any personal information which we may hold about you as a result of our information collection practices set out in this Privacy Policy, or if you wish to comment on or query our Privacy Policy, make an inquiry or correction regarding any personal information relating to you which we may hold, or if you have a complaint about our compliance with the DPPs, please contact the Company’s Privacy Officer on the contact details listed below.

A reasonable access fee may be charged to cover our costs of providing the information to you.
Variation

This Privacy Policy may be varied by us from time to time by us amending this Privacy Policy as published on our websites or by notice to you.

You agree that this Privacy Policy as so varied will apply to our collection and use of your personal information unless your express consent is required under applicable law.
Minor

We do not sell products for purchase by children. If you are under 18 years old, you may use our website only with the involvement of a parent or guardian.
No Spam, Spyware, or Virus

Spam, spyware or virus is not allowed on Platform. Please set and maintain your communication preferences so that we send communications to you as you prefer. You are not licensed or otherwise allowed to add other users (even a user who has purchased an item from you) to your mailing list (email or physical mail) without their express consent. You should not send any messages which contain spam, spyware or virus via the Platform. If you would like to report any suspicious messages, please contact us at our email address below.
Our Right

YOU ACKNOWLEDGE AND AGREE THAT WE HAVE THE RIGHT TO DISCLOSE YOUR PERSONAL INFORMATION TO ANY LEGAL, REGULATORY, GOVERNMENTAL, TAX, LAW ENFORCEMENT OR OTHER AUTHORITIES OR THE RELEVANT RIGHT OWNERS, IF LAZADA HAS REASONABLE GROUNDS TO BELIEVE THAT DISCLOSURE OF YOUR PERSONAL INFORMATION IS NECESSARY FOR THE PURPOSE OF MEETING ANY OBLIGATIONS, REQUIREMENTS OR ARRANGEMENTS, WHETHER VOLUNTARY OR MANDATORY, AS A RESULT OF COOPERATING WITH AN ORDER, AN INVESTIGATION AND/OR A REQUEST OF ANY NATURE BY SUCH PARTIES. TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, YOU AGREE NOT TO TAKE ANY ACTION AND/OR WAIVE YOUR RIGHTS TO TAKE ANY ACTION AGAINST US FOR THE DISCLOSURE OF YOUR PERSONAL INFORMATION IN THESE CIRCUMSTANCES.
Miscellaneous

Nothing in this Privacy Policy shall be read or applied so as to exclude, restrict or modify or have the effect of excluding, restricting or modifying any obligation or right implied by law and which by law cannot be excluded, restricted or modified.

Headings used in this Privacy Policy are for convenience only and shall be ignored in construing this Privacy Policy.

References to ‘include’ and like words are by way of example only and are without limitation.
Contact Details

If you wish to withdraw your consent to our use of your personal information, request access and/or correction of your personal information, have any queries, comments or concerns, or require any help on technical or cookie-related matters, please feel free to contact us (and our Data Protection Officer) through our contact us page.

60 Macpherson Road
Block 1 # 08-08
Siemens Centre,
Singapore 348615

A ‘cookie’ is a small text file containing information which is stored on your computer. Cookies are only used for technical reasons and to facilitate your use of a website. One type of cookie will save a file permanently on your computer. It can thereafter be used to customise this website based on the user’s choices and interests. Another common type of cookie is the “session cookie”. When you visit a website, session cookies are sent between your computer and the server to collect information. Session cookies are not saved once you close your web browser. For more information about how cookies work, please be referred to www.allaboutcookies.org.
The cookies that ASSA ABLOY use on this website are (how long a cookie is saved is specified within parentheses after each denomination):
.ASPXROLES (session) – a cookie which stores role names for users, in order to tell the role of the logged-on user. Only used for websites with a password protected area.
.ASPXAUTH (session) – used in order to determine if a user is authorised to access or not and, only once a user has logged on. Used for websites with a password protected area only.
.LoginC (session) – used in order to see which user is logged-on. Only used for websites with a password protected area.
backgroundImageIndex (session) – used for the reference home page to set up the starting image of the slideshow.
ASP.NET_SessionId (session) – ASP.NET uses this cookie to keep track of requests made during a particular session. It enables the retention of and separation of different users. Only used for websites with a password protected area.
We are continuously working to improve assaabloy.com. In order to do this we use Google Analytics to analyse our users behaviour on an anonymous and aggregated level.
We also allow our web analysis tool, Google Analytics, to place and manage cookies on this website. The following cookies are placed by Google Analytics to log data about visits and visitors of this website. The statistics are used to improve the user experience of this website:

_utma (two years)
_utmz (six months)
_utmc (session)
_utmb (30 minutes)
_utmt (ten minutes)

If you do not wish to accept cookies you can change your web browser’s settings to automatically deny the storage of cookies or to inform you when a website wants to store cookies on your computer. Previously stored cookies can also be deleted through the web browser. More information can be found through your web browser’s support pages. Please note that certain areas and functions on this website require cookies and may not function if cookies are deleted or declined.

For more information regarding the cookies used on this website please contact us at cookies@assaabloy.com.

Cookie	Domain	Purpose	Stored information	Duration	Sharing
[State the name of the cookie]	[State the domain name of the cookie]	[State the purpose of the cookie]	[State what information is stored through the cookie]	[State how long the cookie is stored]	[State if the cookie shares information with any third party.]
guest-view		Stores the Order ID that guest shoppers use to retrieve their order status.	Order id
Login_redirect		Destination page	Preserves the destination page the customer was navigating to before being directed to log in.
mage-messages		Error messages	Tracks error messages and other notifications that are shown to the user, such as the cookie consent message, and various error messages, The message is deleted from the cookie after it is shown to the shopper.
product_data_storage		Product id	Stores configuration for product data related to Recently Viewed / Compared Products.
recently_compared_product		Product id	Stores product IDs of recently compared products.
recently_compared_product_previous		Product id	Stores product IDs of previously compared products for easy navigation.
recently_viewed_product		Product id	Stores product IDs of recently viewed products for easy navigation.
recently_viewed_product_previous		Product id	Stores product IDs of recently previously viewed products for easy navigation.
stf		Time	Records the time messages are sent by the SendFriend (Email a Friend) module.
X-Magento_Vary		Configuration setting	Configuration setting that improves performance when using Varnish static content caching.
form_key		Form key	A security measure that appends a random string to all form submissions to protect the data from Cross-Site Request Forgery (CSRF).
mage-cache-sessid		sessionID	The value of this cookie triggers the cleanup of local cache storage. When the cookie is removed by the backend application, the Admin cleans up local storage, and sets the cookie value to “true.”
mage-cache-storage		Local storage of visitor-specific content	Local storage of visitor-specific content that enables ecommerce functions.
mage-cache-storage-section-invalidation		Forces local storage of specific content sections that should be invalidated	Forces local storage of specific content sections that should be invalidated.
persistent_shopping_cart		Cart key	Stores the key (ID) of persistent cart to make it possible to restore the cart for an anonymous shopper.
private_content_version		Random unique number	Appends a random, unique number and time to pages with customer content to prevent them from being cached on the server.
section_data_ids		Customer specific information	Stores customer-specific information related to shopper-initiated actions such as display wish list, checkout information, etc.
store		Store locale	Tracks the specific store view / locale selected by the shopper.
__utma		sessions	Distinguishes shoppers and sessions .This cookie is created when the JavaScript library executes and there is no existing __utma cookie. The cookie is updated every time data is sent to Google Analytics.
__utmt		Throttle request rate	Used to throttle request rate.
__utmb		New session/visits	Determines new sessions/visits. This cookie is created when the JavaScript library executes and there is no existing __utmb cookie. The cookie is updated every time data is sent to Google Analytics.
_utmz		Traffic source	Saves the traffic source or campaign that explains how the shopper reached your site. The cookie is created when the JavaScript library executes, and is updated every time data is sent to Google Analytics.
__utmv		visitor-level custom variable data	Stores visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor-level custom variable. This cookie is updated every time data is sent to Google Analytics.

This notice covers the products, software, applications and services which are Yale-branded and sold within Southeast Asian regions, including without limitation, Yale smart products broadly Smart Locks, Digital Safes and Accessories (“Products”) and associated mobile applications, the Yale Home mobile app, including corresponding services and web portals (collectively “Services”). Yale smart products and associated Services are aimed at use by adults and not children. You should be at least the age of majority in the country where you live to Home and use the Services. If a person under the age of majority intends to make use of a Yale smart product or associated Services, it must be with the permission of that person's parent or guardian

ASSA ABLOY, its affiliated companies and subsidiaries (collectively “ASSA ABLOY”, “we”, or “us”) are committed to protecting your personal data when you use the Services. The full list of ASSA ABLOY subsidiaries is available here . The purpose of this Privacy Notice is to describe how we collect, use and process the personal data that we receive in connection with your use of the Services, as follows:

How we treat data relating to the Yale Home products/Services
What personal data we may collect
How and why we use your personal data
Who and where is your personal data transferred to
How long will we store your personal data
How we protect your personal data
Your rights
Cookies
How we can make changes to this notice
Contact us

Please click on the links above to navigate directly to the relevant section of this privacy notice. The first link relates to Yale Home products only, whereas the remainder of the notice relates to all personal data Yale process across its range of smart products, including Yale Home products.

Yale Smart products and services are offered by Security & Risk Communications Limited (trading as Yale), registration number 417550, of Parkway Business Centre, Ballymount, Dublin 24, which is the “data controller” for the purposes of registering an account for the App and your use of the Services to operate your products. Security & Risk Communications Ltd is part of the ASSA ABLOY Group of companies.

For other processing activities which are not relating to the operation and management of the Services, but are related to your use of the Yale smart products, such as when you contact customer support or when Yale send you marketing communications in accordance with your preferences. The list of the "data controller" responsible for the processing of your personal data is here.

How we treat data relating to the Yale Home products/Services:

What personal data do we collect for Yale Home products/Services?
Who and where will your personal data be transferred to?
Invitees

What personal data do we collect for Yale Home products/Services?

Personal Data We Require in connection with Yale Home Products, including the purchase, delivery and installation of Yale Home Products or queries relating to these Products

When you purchase any Yale Home Products or send us queries or requests in relation to the Yale Home Products, we will collect information such the following:

Your name
Email address
Home address
Delivery address
Telephone number.

Personal data we require for use of the Services

When you download the App and in order to use the Services, we require you to establish an account and collect and store the following:

Name
Email address
Password
Telephone number
Product ID
User verification identifiers.

Personal data collected based on your use of the Services

About you and others

We collect personal data that you may provide about yourself, such as user-name, as well as personal data about other people who have access to your products, such as other family members, guests, service providers like gardeners, house cleaners and/or others (“Invitees”). For example, you may include email addresses and telephone numbers of Invitees who you are allowing to access your products, as well as the unique pin codes or user codes you may create for them.

We may ask for access to your contact list and you may consent to providing access to such list which includes personal data.

When setting up your products we will gather details about the positioning and use of the products, for example you can name a device or a ‘security area’ within your property, such as kitchen or garage.

Location

If you enable the Auto-Unlock feature for a smart door lock and disarming prompts for an alarm system, the App will request your consent to track your location in order to determine when your device nears products that you have permission to access (e.g. when you are near home). Location information will only be stored on your device, and not by Yale. This information will tell your mobile device to start listening for your product more often (increasing the polling). This improves the device’s performance and saves your mobile device’s battery life. When you provide us with the personal data of any Invitees or third parties, where required by applicable law, you confirm that you have provided this Privacy Notice to such third parties and that you have obtained their consent for the disclosure of their personal data to us as well as our subsequent processing.

Cameras

If you have a camera, it will capture image recordings of the areas in view of the camera, depending on where you position it around your property. It may also capture audio as part of the recording depending on the product used and the settings selected. As a result, the recordings may be of you and your family and friends, as well as other visitors to your property. The images captured can be limited by making use of the Privacy Zone feature, which allows you to black-out areas in the image when they are recorded or live-streamed.

You are always in control of who can see your recordings. In order for someone other than you to access and view your recordings, you must provide your permission. This could be done by providing access to an Invitee, or to Yale in the event of a security concern at your property when you subscribe to our 24/7 monitoring service so we can determine if it is a false alarm or whether the police should be notified or a security guard sent to your home. We take the security of our customer’s recordings very seriously and use a range of measures to keep recordings safe, such as encryption and using a two-step verification process when a new device is used to sign in to an account to view recordings.

Some cameras include detection features, allowing detection of people, pets, vehicles and parcels. You can then customize notifications based on what is detected. These detection features do not recognize individuals or specific vehicles, and as such Yale does not process personal data in order to provide these features.

In many countries there are data protection laws, such as the General Data Protection Regulation (GDPR), which may apply to your use of our camera and CCTV products. It is your responsibility to make sure your use of our products complies with relevant data protection laws. As an example, you should consider displaying a notice to inform visitors to your property that you are capturing visual and audio recordings, and make use of the ‘privacy zone’ feature to help you avoid capturing images of neighbouring properties or public places. You should also consider when and with whom you share recordings, and where they are shared. For example, posting a recording on social media may affect the privacy rights of individuals captured within the recording. If you are unsure whether your intended use of a camera or CCTV system complies with data protection laws in your country, you should refer to the data protection authority for your country. Details of data protection authorities can be found in the ‘Your rights’ section below.

Personal data we automatically collect

When you use the App, we will create a user ID. In addition, we also gather the following information for purposes of providing the Services when you download the App and/or access the Services:

Usage data about how and when you interact with the Services
Product status
Logs of those who lock/unlock your products
The people that you invite to use the Services and product
Those people who may invite you to use their products.

We also collect the following information about the devices on which the App is downloaded and the products you use:

Operating system of the device on which the App is downloaded (e.g. you, Guests)
The version of the App on such devices
Information about your products, including serial numbers, MAC address, software versions on such products and installation dates.

Personal Data we receive when you use third party products and services

If you access the Services through a third-party (e.g. by managing your device via your television remote or connecting your device to your home security system), use a third-party application or service through the “Works With” feature, otherwise use a third-party service provider in connection with the Services and products, or request or authorize us to give access or data to a third-party service provider (e.g. a delivery service, property management or rental service), then that third party will send data about you and your Invitees, such as User ID.

We will tell you when it is mandatory for you to provide us with personal data – if you do not provide us with such requested personal data, you may not be able to use the Services, Product or the App.

Who and where will your personal data be transferred to?

We will transfer personal data for the purposes set out in the section entitled “How and why we use your personal data”;

To other organisations of the ASSA ABLOY Group which support the manufacturing and operation of the Yale Home products and Services.
To third parties which provide support services connected to the Yale Home products and Services and its functions, but only to the extent necessary to provide these services, for example, to Amazon Web Services who may store your personal data on our behalf, or to an SMS service provider to allow us to send you one-time verification codes during the registration process or when you subsequently sign in to the App.
With third parties that provide support services for some existing Yale Home products and Services, such as for customer support purposes.
To Digital Analytics providers who provide tools that help us improve your experience, as well as Market Research agencies which support us to understand how our products are used and viewed by customers. These service providers may only use your personal data in accordance with our instructions and this Privacy Notice.
To your Invitees when you invite them to access your products. For example, if you invite a guest to access your products, then we will share certain elements of your information with them, such as your name, in order for your guest to understand the invite and access the product.
To third parties that you choose, such as when you use the “Works With” feature of the Yale Home app, to connect your products with such third party products or services, oruse a method of connection initiated via a third party product, service or application.
To a buyer or a potential future buyer of our business.
As required by law

Invitees

As part of our Services, you may give Invitees permission levels to access your products - e.g. to unlock and lock your door, and possibly even to pass this access along to others. Needless to say, you must take care when choosing the people that you invite and the level of access that you choose to give them. You are responsible for all uses of your account, so be careful to secure this information and only give access to people you trust. Additionally, certain portions of your personal data, as well as other information about your use of the Service and your products may be shared with Invitees, such as your name and the status of the lock (e.g. locked or unlocked).

In connection with the guest invitation process, we may ask for access to your contact list. We will only store information for contacts that you add as guests. We will only access and store such information with your express consent.

If you are an Invitee, we collect your personal data when you use the Services and products, as set forth in this Privacy Notice. All such information (including your Service usage information) is subject to, and will be used and disclosed as set forth in, this Privacy Notice.

What personal data we may collect?

In addition to the information described in the section above “What personal data do we collect for Yale Home Products/Services?”, we collect and store the information set out in the table below when you register for and use the Services:

App	User submitted	Gathered information
Yale Alarm	Telephone number, email address, password, pictures	Device ID, IP address, activity logging
Yale View	Email address, password, pictures	Device ID, recording image thumbnail (to help customers navigate recording lists), activity logging, IP address
Yale Home View	Email address, password	Device ID, IP address, activity logging
Yale CCTV	None	Device ID, IP address, activity logging
Yale Conexis L1	Name, email address	Device ID, activity logging
Yale Home (for further information see “What personal data do we collect for Yale Home products/Services?”)	Name, email address, password, telephone number, product ID and user verification information, pictures	Device ID, IP address, activity logging

How and why we use your personal data?

Where required by applicable law, we will obtain your consent to the collecting, using and/or disclosing of your personal data.

Why do we process this personal data?	What is the legal basis for such processing?
To provide you with the service you request when using the product. This may include processing your purchase of the product and delivering and installing the product, identifying/authenticating you when you use a Yale app, providing any features and functionality in a Yale app and the products that you elect to use, maintenance which includes software updates, and communicating with you specific to the Services.	Using your personal data in this way is necessary for us to respond to your request. We are performing our obligations under the agreement we have with you to provide the services you have requested. We are unable to provide the services without processing your personal data.
To personalise the Services for purposes of you signing in and using the Services and your products, including to set up and manage your account, for example by providing customer support and sending you notifications of changes to your account details.	Using your personal data in this way is necessary for us to provide you with the service. We are performing our obligations under the agreement we have with you to provide the services you have requested. If we are prohibited from processing your personal data in this way we will be unable to manage your account and our service to you will deteriorate or be terminated.
To record calls in relation to our provision of customer services	Prior to the call commencing you will be told the call is being recorded. Record telephone calls is within Yale’s legitimate interests to enable us to provide a better quality service and to ensure we respond efficiently to your query.
To ensure only you and your Invitees have access to the products.	We are performing our obligations under the agreement we have with you to provide the services you have requested.
To share data with third parties, such as using the ‘Works With’ feature of the Yale Home app, to allow products to be operated via third party products or services, or to allow a service provider to access your property using the Yale In-Home Service.	We share your data to these third parties based on your consent and under your instruction.
To protect the security of our services and products, to detect or prevent unauthorized use of the service or product and / or to detect and prevent fraud, virus attacks, etc.	It is in our legitimate interests to process personal data in maintaining the security of your personal data and the integrity of our services and networks.
To carry out statistical analysis about the product to better understand how our product is used and make improvements.	It is in our legitimate interest to look at this information to understand how our product is being used and manage and to improve the service we can provide to you and other users. Since the personal data that we will process for these purposes is limited and often in an aggregated and anonymous format, we have concluded that our legitimate interest to conduct the improvements and analysis does not impede your privacy interest.
To invite you to participate in market research.	It is in our legitimate interest to gain insight into the performance of our services and to research new business opportunities.
To send you communications about relevant products or services which may be of interest.	We may send you communications about products and services which may be of intertest to you. We may rely on consent, where you have provided it. We may also, where appropriate, rely on our legitimate interest to send such communications. You can unsubscribe from marketing emails at any time using the unsubscribe link in each email we send to you. You can also object to receiving all direct marketing, just let us know using the details in the ‘Contact us’ section below.
To comply with legal requirements to which we are subject, such as tax, accounting/financial reporting requirements, mandatory disclosures and/or law enforcement.	Using your personal data in this way is necessary for us to comply with our legal obligations.

Who and where is your personal data transferred to?

We may transfer your personal data for the purposes set out above:

To organisations of the ASSA ABLOY Group, whether or not going to market as ASSA ABLOY, that market, sell and support our solutions in your country.
To third parties who provide services connected to this product or its functions (including payment processors, insurance companies, IT support services and third-party vendors involved in sending marketing communications), but only to the extent necessary to provide these services, for example, to Amazon Web Services who may store your personal data on our behalf.
To Invitees or third parties that you have requested we send your personal data to, for example when using the “connected to” or “Works with” functions on some devices (see “How we treat data relating to the Yale Home products/Services”).
When required by law, including to government agencies and institutions, where legally required.
To a buyer or a potential future buyer of our business. We do not sell or rent your personal data to third parties.

Some recipients are located in jurisdictions outside the EU/European Economic Area (EEA) or the place where you are accessing our Products, Services and the App from (“Relevant Jurisdiction”). As in some cases these jurisdictions have a lower level of protection than that within the Relevant Jurisdiction, when transferring personal data to jurisdictions outside the Relevant Jurisdiction, we put in place measures (such as the standard contractual clauses approved by the European Commission) to ensure a sufficient level of protection for your personal data.

We take measures to protect all personal data transferred to a third party, or to other jurisdictions, in accordance with applicable data protection laws. A list of jurisdictions and recipient entities can be found here.

ASSA ABLOY Singapore Pte Ltd

ASSA ABLOY Opening Solutions Malaysia Sdn BHD

ASSA ABLOY Vietnam Company Ltd

ASSA ABLOY (Thailand) Limited

ASSA ABLOY Hong Kong Ltd

PT ASSA ABLOY Indonesia

ASSA ABLOY Philippines

ASSA ABLOY Hong Kong Ltd (Taiwan Branch)

Privacy policies of other websites

When request that your information is shared with a third party, such as if you use the “Works With” feature in the Yale Home app, you may be linked to third-party services and websites that you choose. Also, when using the apps, you may use features that link you to social media websites, such as Facebook or Twitter, for example if you chose to share a CCTV recording using the share functionality provided by your device operating system. We are not responsible for the privacy practices or content of any of these third parties or the linked sites. Linked sites may collect personal data from you that is not subject to our control. We encourage you to review the privacy policies on any linked website you visit.

How long will we store your personal data?

We store and use personal data for as long as necessary to fulfil the purpose for which the data has been collected, and in accordance with our internal record retention schedule. This means that we delete your personal data when such data is no longer necessary to process a request, or to manage your account or our client relationship. Statistics which have been anonymised may be saved for longer.

How do we protect your personal data?

We put in place reasonable measures to protect your personal data. For example, only authorized company personnel have access to your personal data.

Once we have received any personal information, we will take reasonable steps to prevent unauthorized access, loss, misuse, modification, interference or disclosure of the information.

In terms of security management systems and security management personnel:

We have a dedicated information security team responsible for the construction of information security system;

We have established relevant security management systems in the collection, storage, transmission and encryption of information, network security, vulnerability management and security incident response;

In terms of technical measures:

We have adopted technical measures such as SSL and TLS to protect the security and confidentiality of information transmission;

We have adopted technical measures such as intrusion detection and prevention systems, network firewalls, anti-virus tools and multi-factor authentication to protect the security and confidentiality of information preservation;

In terms of security event handling:

We have developed security incident reporting and response management systems, such as cybersecurity incident response plans and cybersecurity incident management systems;

If you provide us with your personal information electronically, including but not limited to over the Internet or through the use of any application, we cannot ensure or warrant the security of any information you transmit to us, and such transmission is at your own risk.

Your rights

In relation to the personal data that we hold about you, depending on the place from which you are accessing our Products, Services or the App and the applicable data protection laws in that place, you may have the right to:

Request a copy of your personal data from our records, as well as information on the ways in which that personal data has been used and disclosed (in Singapore, in the 12 months prior to your request);
Ask that we correct, supplement, or your personal data (though this may mean that we cannot process requests, or that your account expires) and request notification to third parties to whom the data have been disclosed of any rectification, erasure or blocking);
Ask us to stop collecting, using or processing your personal data (for example as regards the use of the data to improve our product), or restrict how we process it (for example if you deem the data to be incorrect);
Request the personal data used to provide you with information you requested, or manage your account or our relationship in a machine-readable format, which you are entitled to transfer to another data controller; and
Withdraw your consent to us processing your data for marketing purposes at any time (free of charge), and, where we have obtained your consent for the collection, use and/or disclosure of your personal data for any other purpose, withdraw your consent to us processing your data for any of these purposes. However, depending on the nature of the consent withdrawn, we may no longer be able to provide you with the Products or Services, and you may not be able to continue using the App.

We may not accept a request to erase your personal data where we require it to comply with a legal obligation or in relation to a legal claim. In addition, depending on the applicable data protection law, these rights may be limited in some situations. We may also request additional information from you before processing your requests for the purposes of verifying your identity or security reasons. Where permitted to do so under applicable law, we may charge a reasonable fee to process your access request.

If you are based in the Philippines, then in addition to the rights described in this section, you have the following additional rights:

We shall indemnify you for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
If your personal information is processed by electronic means and in a structured and commonly used format, you have the right to obtain from us a copy of data undergoing processing in an electronic or structured format, which should be in a commonly used format that allows for further use.

For information about how to requests to exercise your rights, see Contact Us below.

If you have a complaint regarding our processing of your personal data and:

you are based in the UK: you are entitled to report this to the ICO (Information Commissioner’s Office) at https://ico.org.uk/concerns or to the supervisory authority where you live or work if different, a list of which can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
If you are based in Hong Kong: https://www.pcpd.org.hk/
If you are based in Singapore: https://www.pdpc.gov.sg/
If you are based in Macau: https://www.gov.mo/en/entity-page/entity-59/
If you are based in the Philippines: https://www.privacy.gov.ph/
If you are based in Taiwan: https://www.ndc.gov.tw/en/Content_List.aspx?n=F01BA39CDAD39B01
If you are based in Indonesia: https://www.kominfo.go.id/
If you are based in Malaysia: https://www.pdp.gov.my/jpdpv2/?lang=en

Cookies

The Yale Smart Product Apps do not use cookies, however the associated websites and web portals may use cookies.

For further information on our use of cookies, please see the relevant Cookie Policy of the web page you are visiting. A link to the policy will be available at the footer of the webpage.

How can we make changes to this privacy notice?

We may update this privacy notice from time to time in response to changing legal, regulatory or operational requirements. If we make any material changes to this Privacy Notice, we will notify you by placing a prominent notice on our website or in the app. Where required under applicable law, we will obtain your consent to such changes; otherwise, your continued use of the product 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 the relevant product(s).

Contact Us

If you have any questions about this Privacy and Legal Notice, please contact us here.

Language of this privacy notice

If this privacy notice is translated into any language other than English, in the event of any discrepancy or inconsistency between the English version and other language versions of this privacy notice, the English version shall prevail.

Legal Notice

Yale App Services Terms and Conditions

Important note: Please read carefully all the terms and conditions of this agreement before you use Yale Products, Yale App services and Yale web portal. Once you register and log in, you are confirming acceptance of all terms and conditions. The Privacy Notice informs you of our policies regarding the collection, use and disclosure of personal data we receive from users of the Products and App By using the Products, App and web portal and where required under applicable law, providing us with your consent, you agree to the collection and use of information in accordance with the Privacy Notice.

Service Regulations

When using Yale App services, the user must comply with the following principles.

Abide by the relevant regulations and policies of your jurisdiction;
Comply with all web service network agreements, terms and conditions;
Login and use only through the Yale App;
Do not use the service for any illegal activity, invasion of privacy or slander purposes;

Updates

Yale reserves the right to updates and make adjustments at any time. Updates may require a relevant update on the users’ equipment (including smart device or product hardware) to the relevant app/operating system or firmware in order to access new functionality and maintain security. Yale cannot guarantee support for old operating systems indefinitely. In addition, Yale retains the right to change or limit some of the functions on the Yale apps and associated products. The user accepts this and the possible impact of this.

Customer Support Access

In cases where customer support requires access to your system, you could be prompted to temporarily change the password. It is your duty to immediately revert back the password after the support case has ended.

Security

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. We recommend that you never re-use any password or share your password with any third party to protect the security of your account. If you believe your account has been compromised, please notify Yale immediately. Yale cannot be held responsible for any losses resulting from your account being compromised.

Changes to this Legal Notice

This Legal Notice is effective as of date specified above and will remain in effect until further notice. We reserve the right to update or change our Legal Notice at any time and you should check this Legal Notice periodically. Your continued use of the Service after we post any modifications to the Legal Notice on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Legal Notice. If we make any material changes to this Legal Notice, we will notify you by placing a prominent notice on our website or in the app.

Jurisdiction and Dispute Resolution

This Legal Notice applies to the use of Yale App’s to operate Yale smart products. In the event of any dispute all parties agree that the jurisdiction and laws of Singapore will be applied. Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The parties agree that any arbitration commenced pursuant to this clause shall be conducted in accordance with the Expedited Procedure set out in Rule 5.2 of the SIAC Rules. The seat of the arbitration shall be Singapore. The Tribunal shall consist of one arbitrator. The language of the arbitration shall be English.

Contact Us

If you have any questions about this Privacy and Legal Notice, please contact us here.

Language of this Legal Notice

If this legal notice is translated into, or appears in a language other than English (as may be required to be prepared and executed to be in compliance with applicable local language laws which a party may be subjected to), the English language version shall control

Notice version 3.0 November 2023

A ‘cookie’ is a small text file containing information which is stored on your computer. Cookies are only used for technical reasons and to facilitate your use of a website. One type of cookie will save a file permanently on your computer. It can thereafter be used to customise this website based on the user’s choices and interests. Another common type of cookie is the “session cookie”. When you visit a website, session cookies are sent between your computer and the server to collect information. Session cookies are not saved once you close your web browser. For more information about how cookies work, please be referred to www.allaboutcookies.org.
The cookies that ASSA ABLOY use on this website are (how long a cookie is saved is specified within parentheses after each denomination):
.ASPXROLES (session) – a cookie which stores role names for users, in order to tell the role of the logged-on user. Only used for websites with a password protected area.
.ASPXAUTH (session) – used in order to determine if a user is authorised to access or not and, only once a user has logged on. Used for websites with a password protected area only.
.LoginC (session) – used in order to see which user is logged-on. Only used for websites with a password protected area.
backgroundImageIndex (session) – used for the reference home page to set up the starting image of the slideshow.
ASP.NET_SessionId (session) – ASP.NET uses this cookie to keep track of requests made during a particular session. It enables the retention of and separation of different users. Only used for websites with a password protected area.
We are continuously working to improve assaabloy.com. In order to do this we use Google Analytics to analyse our users behaviour on an anonymous and aggregated level.
We also allow our web analysis tool, Google Analytics, to place and manage cookies on this website. The following cookies are placed by Google Analytics to log data about visits and visitors of this website. The statistics are used to improve the user experience of this website:
We also allow our web analysis tool, Google Analytics, to place and manage cookies on this website. The following cookies are placed by Google Analytics to log data about visits and visitors of this website. The statistics are used to improve the user experience of this website:

_utma (two years)

_utmz (six months)

_utmc (session)

_utmb (30 minutes)

_utmt (ten minutes)
If you do not wish to accept cookies you can change your web browser’s settings to automatically deny the storage of cookies or to inform you when a website wants to store cookies on your computer. Previously stored cookies can also be deleted through the web browser. More information can be found through your web browser’s support pages. Please note that certain areas and functions on this website require cookies and may not function if cookies are deleted or declined.
For more information regarding the cookies used on this website please contact us at cookies@assaabloy.com.

Cookie	Domain	Purpose	Stored information	Duration	Sharing
[State the name of the cookie]	[State the domain name of the cookie]	[State the purpose of the cookie]	[State what information is stored through the cookie]	[State how long the cookie is stored]	[State if the cookie shares information with any third party.]
guest-view		Stores the Order ID that guest shoppers use to retrieve their order status.	Order id
Login_redirect		Destination page	Preserves the destination page the customer was navigating to before being directed to log in.
mage-messages		Error messages	Tracks error messages and other notifications that are shown to the user, such as the cookie consent message, and various error messages, The message is deleted from the cookie after it is shown to the shopper.
product_data_storage		Product id	Stores configuration for product data related to Recently Viewed / Compared Products.
recently_compared_product		Product id	Stores product IDs of recently compared products.
recently_compared_product_previous		Product id	Stores product IDs of previously compared products for easy navigation.
recently_viewed_product		Product id	Stores product IDs of recently viewed products for easy navigation.
recently_viewed_product_previous		Product id	Stores product IDs of recently previously viewed products for easy navigation.
stf		Time	Records the time messages are sent by the SendFriend (Email a Friend) module.
X-Magento_Vary		Configuration setting	Configuration setting that improves performance when using Varnish static content caching.
form_key		Form key	A security measure that appends a random string to all form submissions to protect the data from Cross-Site Request Forgery (CSRF).
mage-cache-sessid		sessionID	The value of this cookie triggers the cleanup of local cache storage. When the cookie is removed by the backend application, the Admin cleans up local storage, and sets the cookie value to “true.”
mage-cache-storage		Local storage of visitor-specific content	Local storage of visitor-specific content that enables ecommerce functions.
mage-cache-storage-section-invalidation		Forces local storage of specific content sections that should be invalidated	Forces local storage of specific content sections that should be invalidated.
persistent_shopping_cart		Cart key	Stores the key (ID) of persistent cart to make it possible to restore the cart for an anonymous shopper.
private_content_version		Random unique number	Appends a random, unique number and time to pages with customer content to prevent them from being cached on the server.
section_data_ids		Customer specific information	Stores customer-specific information related to shopper-initiated actions such as display wish list, checkout information, etc.
store		Store locale	Tracks the specific store view / locale selected by the shopper.
__utma		sessions	Distinguishes shoppers and sessions .This cookie is created when the JavaScript library executes and there is no existing __utma cookie. The cookie is updated every time data is sent to Google Analytics.
__utmt		Throttle request rate	Used to throttle request rate.
__utmb		New session/visits	Determines new sessions/visits. This cookie is created when the JavaScript library executes and there is no existing __utmb cookie. The cookie is updated every time data is sent to Google Analytics.
_utmz		Traffic source	Saves the traffic source or campaign that explains how the shopper reached your site. The cookie is created when the JavaScript library executes, and is updated every time data is sent to Google Analytics.
__utmv		visitor-level custom variable data	Stores visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor-level custom variable. This cookie is updated every time data is sent to Google Analytics.

The Company

Customer Privacy

Collection, Holding, Use and Disclosure of personal information

How we collect personal information

The kind of personal information we collect

How we hold your personal information

How we use your personal information

Who we disclose your personal information to

Withdrawal of Consent

Updating Your Personal Information

Accessing Your Personal Information

Cookies

Security

Access to and correction of personal information

Variation

Minor

No Spam, Spyware, or Virus

Our Right

Miscellaneous

Contact Details

What personal data do we collect for Yale Home products/Services?

What personal data we may collect?

How and why we use your personal data?

Who and where is your personal data transferred to?

How long will we store your personal data?

How do we protect your personal data?

Your rights

Cookies

How can we make changes to this privacy notice?

Contact Us

Language of this privacy notice

Legal Notice

Yale App Services Terms and Conditions

Service Regulations

Updates

Customer Support Access

Security

Changes to this Legal Notice

Jurisdiction and Dispute Resolution

Contact Us

Language of this Legal Notice