Yale Smart Products - Privacy Notice - South East Asia

Personal Data We Require in connection with Yale Home Products, including the purchase, delivery and installation of Yale Home Products or queries relating to these Products

When you purchase any Yale Home Products or send us queries or requests in relation to the Yale Home Products, we will collect information such the following:

• Your name
• Email address – This is optional, but we recommend you provide your email address which allows a second way to verify your identity, helping to increase your account security
• Home address
• Delivery address
• Telephone number.

Single sign-on services

We allow you to use providers of single sign-on services (such as Google, WeChat, or Apple) with whom you already have an account to create a Yale Home account. You can decide what personal data we can see and use when creating an account using a single sign-on service. For more information about how your personal data may be processed when you use such a single sign-on service, please refer to the single sign-on service provider’s privacy notice.

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:

• Name
• Email address
• Password
• Telephone number
• Product ID
• User verification identifiers.

Personal data collected based on your use of the Services

About you and others

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, as well as the unique pin codes or user codes you may create for them. When you provide us with the personal data of any Invitees or third parties, where required by applicable law, you confirm that you have provided this Privacy Notice to such third parties and that you have obtained their consent for the disclosure of their personal data to us as well as our subsequent processing.

We may ask for access to your contact list and you may consent to providing access to such list which includes personal data.

When setting up your products we will gather details about the positioning and use of the products, for example you can name a device or a ‘security area’ within your property, such as kitchen or garage.

Location

If you enable the Auto-Unlock feature for a smart door lock and disarming prompts for an alarm system, 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 by Yale. This information will tell your mobile device to start listening for your product more often (increasing the polling). This improves the device’s performance and saves your mobile device’s battery life.

Fingerprints

Certain products contain a fingerprint scanner, allowing the use of a fingerprint as an approved credential to operate a product. For instance, a fingerprint can be used to open a smart door lock, in the same way as using a pin code. Products containing a fingerprint scanner do not store an image of a fingerprint when one is registered. Instead, the fingerprint is stored as a digital representation in the form of a binary code. This code cannot be reversed to create a copy of a fingerprint. The fingerprint data is encrypted and only stored in the device. Yale cannot view or access the fingerprint data and it is not backed up to a cloud.

You are in control of how your fingerprint is used. It is not necessary for a fingerprint to be registered for a product to function. Fingerprint functionality is provided for the convenience and preference of customers, so you can choose to enroll a fingerprint. We therefore rely on your explicit consent to process fingerprint data. If you change your mind and do not want to use a fingerprint as a credential, you can delete it from the device at any time.

Cameras
If you have a camera, it will capture image recordings of the areas in view of the camera, depending on where you position it around your property. It may also capture audio as part of the recording depending on the product used and the settings selected. As a result, the recordings may be of you and your family and friends, as well as other visitors to your property. The images captured can be limited by making use of the Privacy Zone feature, which allows you to black-out areas in the image when they are recorded or live-streamed.

You are always in control of who can see your recordings. In order for someone other than you to access and view your recordings, you must provide your permission. This could be done by providing access to an Invitee, or to Yale in the event of a security concern at your property when you subscribe to our 24/7 monitoring service so we can determine if it is a false alarm or whether the police should be notified or a security guard sent to your home. We take the security of our customer’s recordings very seriously and use a range of measures to keep recordings safe, such as encryption and using a two-step verification process when a new device is used to sign in to an account to view recordings.

Some cameras include detection features, allowing detection of people, pets, vehicles and parcels. You can then customize notifications based on what is detected. These detection features do not recognize individuals or specific vehicles, and as such Yale does not process personal data in order to provide these features.

In many countries there are data protection laws, such as the General Data Protection Regulation (GDPR), which may apply to your use of our camera and CCTV products. It is your responsibility to make sure your use of our products complies with relevant data protection laws. As an example, you should consider displaying a notice to inform visitors to your property that you are capturing visual and audio recordings, and make use of the ‘privacy zone’ feature to help you avoid capturing images of neighbouring properties or public places. You should also consider when and with whom you share recordings, and where they are shared. For example, posting a recording on social media may affect the privacy rights of individuals captured within the recording. If you are unsure whether your intended use of a camera or CCTV system complies with data protection laws in your country, you should refer to the data protection authority for your country. Details of data protection authorities can be found in the ‘Your rights’ section below.

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

In-app news & offers

In the Explore section of the app we provide information and news about new products, offers and services. This information is provided to all app users at a country / language level, and is not targeted to individual app users based on the products they use in the app. If you would like to receive tailored offers based on the products and services you receive from Yale, you can provide consent to do so. If you choose to provide consent, we will use details of the products you hold and use to provide you with tailored in-app messages and notifications about Yale products and services which we think you’ll love. For example, if you use a smart door lock and an alarm system, we may send you an offer about a camera which we think will work with and complement your existing products to improve your overall home security. You can unsubscribe at any time by updating your preferences in the App Consents section of the app menu.

We will tell you when it is mandatory for you to provide us with personal data – if you do not provide us with such requested personal data, you may not be able to use the Services, Product or the App.

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 which support the manufacturing and 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.

In addition to the information described in the section above “What personal data do we collect for Yale Home Products/Services?”, we collect and store the information set out in the table below when you register for and use the Services:

Where required by applicable law, we will obtain your consent to the collecting, using and/or disclosing of your personal data.

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

• To organisations of 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 this product or its functions (including payment processors, insurance companies, IT support services and third-party vendors involved in sending marketing communications), 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 devices (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 jurisdictions outside the EU/European Economic Area (EEA) or the place where you are accessing our Products, Services and the App from (“Relevant Jurisdiction”). As in some cases these jurisdictions have a lower level of protection than that within the Relevant Jurisdiction, when transferring personal data to jurisdictions outside the Relevant Jurisdiction, we put in place measures (such as the standard contractual clauses approved by the European Commission) to ensure a sufficient level of protection for your personal data.

We take measures to protect all personal data transferred to a third party, or to other jurisdictions, in accordance with applicable data protection laws. A list of jurisdictions and recipient entities can be found here.

ASSA ABLOY Singapore Pte Ltd

ASSA ABLOY Opening Solutions Malaysia Sdn BHD

ASSA ABLOY Vietnam Company Ltd

ASSA ABLOY (Thailand) Limited

ASSA ABLOY Hong Kong Ltd

PT ASSA ABLOY Indonesia

ASSA ABLOY Philippines

ASSA ABLOY Hong Kong Ltd (Taiwan Branch)

Privacy policies of other websites

When 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 X, 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 and use personal data for as long as necessary to fulfil the purpose for which the data has been collected, and in accordance with the requirement of applicable laws and 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.

We put in place reasonable measures to protect your personal data. For example, only authorized company personnel have access to your personal data.

Once we have received any personal information, we will take reasonable steps to prevent unauthorized access, loss, misuse, modification, interference or disclosure of the information.

In terms of security management systems and security management personnel:

We have a dedicated information security team responsible for the construction of information security system;        

• We have established relevant security management systems in the collection, storage, transmission and encryption of information, network security, vulnerability management and security incident response;         

In terms of technical measures:

We have adopted technical measures such as SSL and TLS to protect the security and confidentiality of information transmission;         

• We have adopted technical measures such as intrusion detection and prevention systems, network firewalls, anti-virus tools and multi-factor authentication to protect the security and confidentiality of information preservation;    

In terms of security event handling:

• We have developed security incident reporting and response management systems, such as cybersecurity incident response plans and cybersecurity incident management systems;

If you provide us with your personal information electronically, including but not limited to over the Internet or through the use of any application, we cannot ensure or warrant the security of any information you transmit to us, and such transmission is at your own risk.

In relation to the personal data that we hold about you, depending on the place from which you are accessing our Products, Services or the App and the applicable data protection laws in that place, you may have the right to:

• Request to access or request for a copy of your personal data from our records, as well as information on the ways in which that personal data has been used and disclosed (in Singapore, in the 12 months prior to your request);
• Ask that we correct, supplement, or your personal data (though this may mean that we cannot process requests, or that your account expires) and request notification to third parties to whom the data have been disclosed of any rectification, erasure or blocking);
• Ask us to stop collecting, using or 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 (or equivalent under applicable law); and
• Withdraw your consent to us processing your data for marketing purposes at any time (free of charge), and, where we have obtained your consent for the collection, use and/or disclosure of your personal data for any other purpose, withdraw your consent to us processing your data for any of these purposes. However, depending on the nature of the consent withdrawn, we may no longer be able to provide you with the Products or Services, and you may not be able to continue using the App.

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. In addition, depending on the applicable data protection law, these rights may be limited in some situations. We may also request additional information from you before processing your requests for the purposes of verifying your identity or security reasons. Where permitted to do so under applicable law, we may charge a reasonable fee to process your access request.

If you are based in the Philippines, then in addition to the rights described in this section, you have the following additional rights:

• We shall indemnify you for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
• If your personal information is processed by electronic means and in a structured and commonly used format, you have the right to obtain from us a copy of data undergoing processing in an electronic or structured format, which should be in a commonly used format that allows for further use.

If you are based in Singapore, then in addition to the rights described in this section, you have the following additional right:

• If your personal information is processed by electronic means and in a structured and commonly used format, you have the right to obtain from us a copy of data undergoing processing in an electronic or structured format, which should be in a commonly used format that allows for further use.

If you are based in Thailand, then in addition to the rights described in this section, you have the following additional rights:

• Request the disclosure of the acquisition of the personal data obtained without your consent; and
• Object to the processing of your personal data, to the extent permitted by law.

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 and:

• you are based in the UK: 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, a list of which can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
• If you are based in Hong Kong: https://www.pcpd.org.hk/
• If you are based in Singapore: https://www.pdpc.gov.sg/
• If you are based in Macau: https://www.gov.mo/en/entity-page/entity-59/
• If you are based in the Philippines: https://www.privacy.gov.ph/
• If you are based in Taiwan: https://www.ndc.gov.tw/en/Content_List.aspx?n=F01BA39CDAD39B01
• If you are based in Indonesia: https://www.kominfo.go.id/
• If you are based in Malaysia: https://www.pdp.gov.my/jpdpv2/?lang=en
• If you are based in Thailand: https://www.pdpc.or.th/

The Yale Smart Product Apps may collect information from your mobile device or Yale product in the event there is a ‘crash’ or an issue, to help us continuously improve our products and services.

Associated Yale 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. Where required under applicable law, we will obtain your consent to such changes; otherwise, 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 the relevant product(s).

If you have any questions about this Privacy and Legal Notice, please contact us here[DLA1] .

 [DLA1]Malaysia: The Personal Data Protection Regulations 2013 require the data user to at least provide the data subject with the following details:

(a) designation of the contact person; (mandatory)

(b) phone number; (mandatory)

(c) fax number, if any;

(d) e-mail address, if any; and

(e) such other related information.

We note from a perusal of this link that the phone number and designation of the contact person from Malaysia are not listed. Please set out this information in the table provided via the link to comply with local data protection laws.

If this privacy notice is translated into any language other than English, in the event of any discrepancy or inconsistency between the English version and other language versions of this privacy notice, the English version shall prevail.

Important note: Please read carefully all the terms and conditions of this agreement before you use Yale Products, Yale App services and Yale web portal. 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 data we receive from users of the Products and App By using the Products, App and web portal and where required under applicable law, providing us with your consent, you agree to the collection and use of information in accordance with the Privacy Notice.

When using Yale App services, the user must comply with the following principles.

1. Abide by the relevant regulations and policies of your jurisdiction;
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;

Yale reserves the right to updates and make adjustments at any time. Updates may require a relevant update on the users’ equipment (including smart device or product hardware) to the relevant app/operating system or firmware in order to access new functionality and maintain security. 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 Yale apps and associated products. The user accepts this and the possible impact of this.

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.

The security of your personal data 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 data, 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.

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.

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 Singapore will be applied. Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The parties agree that any arbitration commenced pursuant to this clause shall be conducted in accordance with the Expedited Procedure set out in Rule 5.2 of the SIAC Rules. The seat of the arbitration shall be Singapore. The Tribunal shall consist of one arbitrator. The language of the arbitration shall be English. 

If you have any questions about this Privacy and Legal Notice, please contact us here.

If this legal notice is translated into, or appears in a language other than English (as may be required to be prepared and executed to be in compliance with applicable local language laws which a party may be subjected to), the English language version shall control

 Notice version (Version 5.0, February 2025)