Australia and New Zealand - Yale Smart Products - Privacy Notice - English

By accessing and/or using the App and/or Services you acknowledge that you have read and understood this Privacy Notice and that you authorise us to collect, hold, use and disclose your Personal data that we receive in connection with your use of the App and/or Services in accordance with this Privacy Notice.

This Privacy Notice applies together with any other applicable terms and conditions that may apply to your relationship and/or engagement with us, including our general Privacy Policy, available here: General Privacy Policy (which applies to your engagement with us other than through the App or Services), as well as our Terms and Conditions available –

• For Australia - https://www.assaabloy.com/au/en/legal/terms-and-conditions-of-trade
• For New Zealand - https://www.assaabloy.com/nz/en/privacy-center/terms-and-conditions

• 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 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 we 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

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”). This will include mobile telephone numbers, as well as other information you may provide in relation to a contact list, such as the name or email address 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.

If you enable the Auto-Unlock feature, 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 on our servers. This information will tell your mobile device to start listening for your lock more often. 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 the 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
• A record of when a product owner sends an invite to another person to use their product

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. by you, 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.

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 product via your television remote or connecting your product 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 us 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 and why we use your personal data”;

• To other organisations of the ASSA ABLOY Group to the extent necessary to support the 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, or use 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.

We collect and store the information set out in the table below when you register for and use the Services:

For Yale View, Yale Home View and Yale CCTV Apps which offer CCTV/IP Camera functionality, recordings are stored locally (where the system is set up) on the product hardware. Yale does not have access to these recordings.

For the Yale View App, a thumbnail image of a recording is stored by Yale, to allow an easily navigated recording list to be presented in the App, so you can quickly identify a relevant recording from the thumbnail image. Thumbnail images are only retained by Yale for 7 days and then deleted.

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

• To other organisations in 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 the 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.
• 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 products (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 countries outside the UK/EU/European Economic Area (EEA). As in some cases these countries have a lower level of protection than that within the UK/EU/EEA, when transferring personal data to countries outside the UK/EU/EEA we use standard contractual clauses approved by the UK government or European Commission as applicable to ensure a sufficient level of protection for your personal data. You can obtain a copy by getting in touch using the details in the ‘Contact us’ section below.

We take measures to protect all personal data transferred to a third party, or to other countries, in accordance with applicable data protection laws.

Privacy policies of other websites

When you 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.

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.

You can contact us via the contact details below to:

• request access to any Personal data which we hold about you;
• comment on or query our Privacy Policy;
• request a correction to your Personal data;
• make a complaint about our compliance with Australian or New Zealand privacy laws (whichever is applicable)

The Company will deal with such a request in accordance with the requirements of the Australian or New Zealand privacy laws (whichever is applicable).

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.

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.

If you have any questions about this Privacy Notice or our processing of your personal data, please contact us:

Notice version 2.1 May 2023