- What personal data do we collect for Yale ACCESS Products/Services?

- Who and where will your personal data be transferred to?

- Invitees

Yale Access products, software, applications and services are offered by Security & Risk Communications, registration number 417550, address Parkway Business Centre, Ballymount, Dublin 12, trading as Yale, which are manufactured, licensed or operated by August Home Inc. (a member of the ASSA ABLOY Group and a wholly owned subsidiary of ASSA ABLOY AB) and which are Yale-branded, including without limitation, the Yale Access mobile app (“App”), including corresponding services and corresponding web portal (collectively “Services”).

For purposes of the Services, Security & Risk Communications, registration number 417550, address Parkway Business Centre, Ballymount, Dublin 12 (“Yale”) is the “data controller” and August Home Inc. is the “processor” responsible for the processing of your personal data.

What personal data do we collect for Yale ACCESS Products/Services?

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: Your name, email, password, telephone number, Product ID and user verification identifiers.

Personal Data collected based on your use of the Services. 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. We may ask for access to your contact list and you may consent to providing access to such list which includes personal data.

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

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 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, 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: 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 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 data about you and your Invitees, such as User ID. 

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 we use that information and why”;

- To August Home, Inc. who is responsible for the processing of your personal data and who in turn may engage third parties to perform functions necessary for us to provide the following for the Services: hosting, development, maintenance, billing services, mobile application functionality, facilitate communications, enable customer support and any features or functionality available as part of the Services, provided only to the extent necessary to provide the Services. August Home and any third party service providers may only use your personal data in accordance with 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.

- 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.

- Digital Analytics providers who provide tools that help us improve your experience. These service providers may only use your personal data in accordance with our instructions.

- To a buyer or a potential future buyer of our business.

- As required by law

Invitees

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 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 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 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.

We collect and store:

- Information according to the table below which you submit in the app in order to obtain information from us.

- In addition to the information you submit we are gathering information according to the table below.

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

- To organizations of the ASSA ABLOY Group, whether or not going to market as ASSA ABLOY, that market, sell and support our solutions in your country, for example, to August Home, Inc. who is responsible for the processing of your personal data in relation to Yale Access Products.

- To third parties who provide customer support services connected to this product or 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 third parties you choose when you use the “Works With” feature of the Services to connect your Products with such third party products or services..

- To Invitees or third parties that you have requested us to 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 Access 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. 

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 data from you that is not subject to our control. We encourage you to review the privacy policies on any linked website you visit.

Some recipients are located in countries outside the EU/European Economic Area (EEA). As in some cases these countries have a lower level of protection than that within the EU/EEA, when transferring personal data to countries outside the EU/EEA we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data. 

These standard contractual clauses can be found at:

https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087 

We take measures to protect all personal data transferred to a third party, or to other countries, in accordance with applicable data protection laws. A list of countries and recipient entities can be provided upon request, see Contact Us below.

We store 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.

Your rights

In relation to the personal data that we hold about you, you have the right to:

- Request a copy of your personal data from our records;

- Ask that we correct or erase your personal data (though this may mean that we cannot process requests, or that your account expires);

- Ask us to stop 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.

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.

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 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, list of which can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Cookies

For further information on our use of cookies, please see our Cookie Policy 

We make use of Google Analytics, an analysis service provided by Google, to help us track usage statistics.

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. 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 this product.

Contact Us 

If you have any questions about this Privacy and Legal Notice, please use our Privacy Contact Centre.

Yale App Services Terms and Conditions

Important note: Please read carefully all the terms and conditions of this agreement before you use Yale App services. 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 Information we receive from users of the App. By using the App, 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.

1) Abide by the relevant regulations and policies of your country;

2) Comply with all web service network agreements, terms and conditions;

3) Login and use only through the Yale App;

4) Do not use the service for any illegal activity, invasion of privacy or slander purposes;

App Upgrades

Yale reserves the right to upgrade and make adjustments at any time. App upgrades may require a relevant upgrade on the users’ equipment to the relevant operating system in order to access new functionality. 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 App. 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 Information 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 Information, 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

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 England & Wales will be applied.

Contact Us

If you have any questions about this Privacy and Legal Notice, please use our Privacy Contact Centre.