What Personal Information do we collect? 

Personal Information We Request for Use of the Services.  When you download the App and in order to use the Services, we require you to establish an account, for which we collect and store the following: your name, email, password, telephone number, the identification number for your locksets (“Products”) and user and account verification identifiers.  

Personal Information collected based on your use of the Services.  When you use the Services, we collect Personal Information that you may provide about yourself, such as user-name, as well as Personal Information about other people who have access to your Products, such as other family members, guests, and 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.  We may ask for access to your contact list, and you may consent to provide access to such list, which includes Personal Information. 

We collect Personal Information that you may include in help requests, customer service correspondence and/or in any feedback, you send to us.  We also collect Personal Information included in messages that you may send from within the App whether those messages are sent to us, an Invitee, or a third party.

Also, if you enable the Auto-Unlock feature, the App will request your consent in order to track your location in order to determine when your App 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 on our servers. This information will tell your mobile device to start listening for your lock more often (increasing the polling). This improves the device’s performance and saves your mobile device’s battery life.

Personal Information we automatically collect.  When you use the App, we will create a user ID for your account and 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 and Products, logs of when your Products are locked/unlocked, logs of those who lock/unlock your Products, the people that you invite to use your Products, and 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: the operating system of the device on which the App is downloaded (e.g., you, your invitees), 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. 

Additionally, if you choose to use the App to connect your Products with other products and services through the “Connected by” feature, we will collect information about your use of those other products.

Personal Information 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 third-party applications or services 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 us data about you, such as an user ID.    

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. You must be careful of the people that you invite and the access that you 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 Information, 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 Information when you use the Services and Products, as set forth in this Privacy Policy.  All such information (including your service usage information) is subject to and will be used and disclosed as set forth in, this Privacy Policy. 

Who and where will your Personal Information be transferred to? 

We will transfer Personal Information for the purposes set out above:

• To third parties to perform services necessary for us to provide the following for the Services: hosting, development, maintenance, billing services, mobile application functionality, facilitate communications/messages, customer support, and any features or functionality available as part of the Services and Products, provided only to the extent necessary to provide the Services.  This includes the processing of data concerning usage of the Services and our Products.  Any third party service providers may only use your Personal Information only according to our instructions. 
• 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.  

Additionally, we may also similarly share your information with your Invitee.

• To third parties that you choose when you use the “Works With” feature of the Services to connect your Products with such third party products or services.
• To affiliated entities when you use the “Connected With” feature in the App for purposes of connecting your Product with the other products and services you use.
• To organizations affiliated with our parent company, the ASSA ABLOY Group.
• With your consent, such as with guest invitations or if you choose to connect our products to work in conjunction with third party products or services. See below for additional information about guest sharing. Please note that when you consent to these transfers, any shared data will then be subject to the privacy policies of those third parties.
• To a buyer or a potential future buyer of our business.
• As required by law.

We take measures to protect all Personal Information transferred to a third party, or to other countries, in accordance with applicable data protection laws and as stated above.

ASSA ABLOY do not sell or rent your Personal Information to third parties. [Link to the Do Not Sell My Personal Information notice]

Privacy policies of other websites.

When you use the “Works With” feature in the App, you may be linked to third-party services and websites that you choose.  Also, when using the App, you may use features that link you to social media websites, such as Facebook or Twitter.  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 Information from you that is not subject to our control. We encourage you to review the privacy policies on any linked website you visit.

Information Retention

We may store collected information for as long as necessary to fulfill the purpose for which the Personal Information has been collected, and in accordance with our internal record retention schedule. If you purchase ASSA ABLOY products or the Services, your billing and shipping address and the last four digits of your credit card information will be stored by ASSA ABLOY and our billing service providers. Lock activity is stored alongside your account information for the duration of your account being active. Doorbell camera photos and videos are available for download through our mobile application for up to thirty (30) days or as referenced in the selected subscription terms of service, unless the information is necessary to be preserved based on a valid law enforcement obligation.

We will delete your personal data when the information is no longer necessary to process a request, at your request, or to manage your account or our client relationship. We will continue to store mobile application use and lock activity, including guest activity, for a period of at least ninety (90) days following account deletion.

We may store any aggregate or anonymous information indefinitely.

Changes to this Policy

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.”

We will make good faith efforts to resolve any requests to correct inaccurate personal data except where (1) the request is unreasonable, (2) requires disproportionate technical effort or expense, (3) jeopardizes the privacy of others or would be impractical. We will comply with the specific time required in the applicable law to address your concerns, free of charge if possible for the business and the allowed number of times, under applicable law guidance.