Privacy Notice

ASSA ABLOY Sales and Marketing Group, Inc. and its affiliates (collectively and individually, "ASSA ABLOY")are 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 ASSA ABLOY Connect Customer Portal (the "Portal"), which will be referred to as "service" in this Notice.

What personal information will ASSA ABLOY process, and why?

A.  ASSA ABLOY will process the personal information set out in this section to provide the   service:

1. Name
2. Email address
3. Job title
4. Mailing address
5. Telephone number
6. Portal access, portal usage

B.  ASSA ABLOY will process the personal information to achieve our business purpose in  developing and updating our products and services in accordance with the following   description.

• To provide the services you sign up for.
  • Access and use of business-related information, pricing, quotes, aknowledgements, invoices, etc.
  • Access to our webshop sites, marketing resources, tools and training sites
• The information we process and collect will come from your use of the application required to use the "service."

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

Legal Basis

We will always use your personal information with a lawful basis when:

• It is necessary for the "Performance of a Contract" (e.g., fulfill a sales order)
• You provide "Consent" for the use of it (e.g., clicked "accept" on the privacy notice page and subsequently used the service, subscribed your email to the news or marketing list)
• We use or share with a service providers your personal information, which is necessary to perform the required business purposes.
• We are "Legally Obligated" (e.g., to fulfill legal and statutory requirements)

You are free to, at any time and without cause, revoke your consent to ASSA ABLOY''s processing of your personal information, however, please note that if you revoke your consent to ASSA ABLOY''s processing of your personal information, it means that ASSA ABLOY will no longer provide access to the service.

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:

• 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 in facilitating the transfer of personal information between your computer or device and our computers or servers (or third party servers which 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 during one of our processes, your personal information may be transferred to, stored, or processed in one of these locations. 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 personal 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 personal 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."

User 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 "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 sell 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 not necessarily 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 do not 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 complete removal of that personal information from our systems or the systems of our service providers.

Right to obtain equal service, even if you exercise your 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" makes use of Google Analytics, an analysis service provided by Google.

Google''s possibility to use and share information collected by Google Analytics about your visits to our application is restricted by the Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html).

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

"Pixels" are small graphics with unique identifiers, which use is to track movements of web users. Different than 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. It is possible that 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 usage information as described above, your selection of the DO NOT TRACK option in your browser may not affect our collection of personal 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.

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 data 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. If we learn that we have collected personal information from an under age of 18, 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 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 which to request this personal information, make a request to Privacy Americas with "California Privacy Rights" as the title of your letter, please mail it to 110 Sargent DR, New Haven CT. 06518.

Our obligations under California law are satisfied as long as we anonymize the personal information or render it invisible to other users and the public; therefore, we are not required to delete the information posted by you.

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."