BACKGROUND

This Privacy Policy (this “Privacy Policy”) forms a part of the End User License Agreement (hereinafter referred to as the "Agreement") and is part of the agreement between you and ASSA ABLOY and relates to the downloading and use of the App to access and use the System. Capitalized terms in this Privacy Policy have the meaning given to them in the Agreement.

ASSA ABLOY is committed to protecting your personal data. This Privacy Policy describes how ASSA ABLOY processes the personal data ("Data") that we receive from you in connection with your downloading and use of the App and how you can contact us if you have additional questions regarding our processing of the Data.

1. THE DATA WE MAY COLLECT, STORE AND PROCESS

We may collect, store and process the following Data:

Your name, phone number, email address(s) and your System user account details such as User Name and Password/PIN;

Technical data and related information about the Device being used by you for accessing and using the App, including unique push ID, operating system, application software and peripherals; and

Information related to the use and performance of the App and of the System as accessed and used via the App.

2. WHY WE COLLECT THE DATA

We collect your Data to:

Be able to grant you the License to the App and the Right to Use the System via the App and to communicate with you about the System and the App;

In addition to the above mentioned use and purposes, we may also use your Data to administrate and improve the App and the System, provide support and updates relating to the System and the App, improve and develop new products, for our internal records, for statistical analysis and to complete your product orders and/or to contact you regarding sales and as a part of our customer relation procedures.

ASSA ABLOY’s collection of Data is based on the need to carry out the processes stipulated above. To the extent that ASSA ABLOY uses the Data to develop the App or the System or other products or for analyzing statistics, the basis for collection and processing of Data is ASSA ABLOY’s legitimate interest to conduct such improvements and analysis.

3. HOW WE OBTAIN DATA

We obtain Data when you download the App, when you fill in the necessary Data to access the System via the App, when you use the System via the App or when you contact us directly concerning the use of the System or the App or from your other transactions or experiences with us or with any other ASSA ABLOY group company.

4. WHO WE MAY DISCLOSE DATA TO

For the stated purposes, Data may be transferred to ASSA ABLOY group companies in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring your Data to countries outside the EU/EEA, ASSA ABLOY uses standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your Data. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

Data collected and stored is exclusively used by companies within the ASSA ABLOY group, except in the following cases where we may submit the data to third parties:

• When required by law or as lawfully ordered by a court or authority of competent jurisdiction;

• To a buyer or a potential future buyer of our business, and/or;

• To service providers appointed by ASSA ABLOY who provides services connected or relating to the App and/or the System or its functions, but only to the extent it is necessary in order to provide you access to and use of the System via the App – for example our service provider(s) which for example sells, administrates, grants access to or hosts, develops and offers support for the App or the System.

ASSA ABLOY will take measures to protect all Data transferred to such third party, or that has been transferred to other countries, in accordance with applicable data protection laws and as stated above.

5. PERIOD OF RETENTION AND USE

ASSA ABLOY stores the Data as long as it is necessary to fulfil the purposes for which the Data has been collected. This means that ASSA ABLOY deletes your Data when the purposes for which it was collected has been fulfilled (for example when you do not wish to use or access the System via the App any more) and such Data is no longer necessary to process a request, fulfill any legal obligations, process an order or to administrate your user account in the System via the App. Statistics which has been anonymised may be saved thereafter.

6. AMENDMENTS

We may amend this Privacy Policy from time to time. When we update this Privacy Policy you will be notified when you access the System via the App and there you will be required to accept the new and updated privacy policy in order to continue to access and use the System via the App.

7. COMPLAINT

If you have a complaint regarding the processing of your Data by ASSA ABLOY you are entitled to report such dissatisfaction to the supervisory authority in the country you are located.

8. YOUR RIGHTS TO ACCESS AND CORRECT THE DATA

You may at any time request the rectification or erasure of your Data. Please note however that deletion could mean that ASSA ABLOY cannot process requests or orders, or that the System cannot be used or accessed via the App or that your user account expires/terminates. You have the right to request a copy of your Data from our records. You have the right to request a limitation of the use of your Data (for example if you deem Data to be incorrect) or the termination of use of your Data (for example as regards the use of the Data to improve the App and/or the System). You are entitled to request a copy of the Data used to process an order, to administrate, access and use the System via the App, in a machine-readable format which you are entitled to transfer to another data controller.

9. CONTACTS

ASSA ABLOY AB (publ), corporate registration number 556059-3575 is responsible for the processing of your Data, and requests to exercise your rights as stated above shall be addressed to ASSA ABLOY AB (publ), P.O. Box 70340, SE-107 23 Stockholm, Sweden with attention to: ASSA ABLOY Group the Personal Data Responsible.