Privacy Policy

Privacy Policy

1. The Company

 

This Privacy Policy (Privacy Policy) sets out the policy of ASSA ABLOY companies as listed in Schedule 1 below (collectively, but not jointly or jointly and severally in any instance, referred to as us, we, our or the Company). Any person, firm, company, government body or other entity who provides Personal or Sensitive Information to us or accesses or uses our websites (our websites) is referred to as you or your.

 

2. Privacy Principles

 

The Privacy Act 1988 (Cth) sets out 13 Australian Privacy Principles (APPs). The APPs can be found on the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au. Similarly, the Privacy Act 2020 (NZ) sets out 13 Information Privacy Principles (IPPs).

The Company respects an individual’s right to personal privacy and is committed to complying with the APPs and IPPs.

 

3. Personal and Sensitive Information

 

In this Privacy Policy we use the terms “Personal Information” and “Sensitive Information”. Where we do so, we mean the following:

”Personal Information” is information or an opinion about you as an identified individual or an individual who is reasonably identifiable, whether or not the information or opinion is true and whether or not it is recorded in a material form.

“Sensitive Information” is a specific subset of Personal Information. It is information about an individual’s health (including predictive genetic information), racial or ethnic origin, political opinions, membership of a political association, professional or trade association or trade union, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices, criminal record, biometric information that is to be used for certain purposes and biometric templates.

It is not common for us to collect or use Sensitive Information in our business arrangements with customers or third parties, however this type of information can have relevance to certain products (such a where those products use biometric data as an access tool) and certain business operations such as our employment-related processes. We’ll always ask for your consent before we collect and use your sensitive information. The only exceptions are when we’re permitted to collect and use that information, or when we’re legally required to do so.

 

4. Acceptance of this Privacy Policy

 

By accessing or using our websites, and/or otherwise providing us with Personal or Sensitive Information, you acknowledge that you have read and understood this Privacy Policy and that you authorise us to collect, hold, use and disclose your Personal or Sensitive Information in accordance with this Privacy Policy and any more specific terms that are disclosed or agreed (as applicable) with you relevant to specific sets of information provided or collected.

 

5. How we collect Personal and Sensitive Information

 

We only collect Personal Information and Sensitive Information that is reasonably necessary for our Company functions and activities and/or our dealings with you.

We collect such information in a number of ways, including:

1. directly from you (such as when you submit a request, send us an email, place an order, complete a survey or register for a promotion, or when you download and use an app relating to one of our products or services);
2. via third party service providers, including credit reporting agencies such as when you submit credit applications to us;
3. from other third party sources such as website analytics or how and when you use our products and services, including technical information;

If you don’t provide Personal or Sensitive Information we request, we may be unable to fulfil purposes stipulated in 8 below.

 

6. The kind of Personal or Sensitive Information we collect

 

The Personal or Sensitive Information we collect depends on the purpose for which it is collected, but generally may include:

1. name and contact details (including your address, email address, telephone number)
2. payment details and transaction history;
3. financial and credit information;
4. information relating to your use of our goods and services, including your user ID and password, video, video and photo images, voice recordings, and usage related to such products and services including location data and device-specific information.

If you are a client or customer, we may also require: your financial and credit information; information relating to your use of our goods and services, including your user ID and password, video, video and photo images, and voice recordings; and usage related to such goods and services, including location data and device-specific information.

If you are our employee, please access the Employee Privacy Notice specific to your country or employer entity, as this contains more specific privacy-related information relating to employee-related Personal and Sensitive Information.

In some circumstances, you may deal with us anonymously or using a pseudonym. However, in most circumstances it is impracticable to do so because if you do not provide us with the Personal and Sensitive Information that we require or if you provide it in a way that does not identify you, we are unlikely to be able to fulfil the purposes mentioned in section 8 below, including providing you with relevant products or services (where relevant).

You agree that any information you do give to us will be accurate, correct and up to date and you will inform us if any of Personal or Sensitive Information changes to ensure that the details we hold about you are up to date and correct.

 

7. How we hold your Personal or Sensitive Information

 

This will depend on the specific information and the circumstances in which it was obtained. Your information may be held by the Company in one or more formats (both physical and electronic, including, in relevant instances, cloud storage provided by our third party service providers).

 

8. How we use your Personal or Sensitive Information

 

Where we use and disclose your Personal or Sensitive Information, we do so to provide you with products and services, and conduct our business. More specifically, that may include one or more of the following purposes, depending on the information and the specific circumstances in which it was collected:

1. to provide you with our goods and services;
2. to process transactions;
3. to provide quality assurance, customer care and assistance;
4. to communicate with you (regarding your transactions, for customer support, to ask you for feedback, or to respond to your enquiries or feedback);
5. to help provide a more personalised experience;
6. for business administration purposes;
7. to improve and enhance our goods and services;
8. to conduct market analysis and data analytics on customer behaviours and insights in relation to our goods and services;
9. to manage or improve our websites and for statistical analysis;
10. where you have provided consent (in accordance, where applicable, with New Zealand's Unsolicited Electronic Messages Act 2007 and APPs 7), to send you direct electronic marketing and/or promotional messages, including news, invitations, information about our activities and general promotional materials;
11. to maintain our relationship with you;
12. to enforce the terms and conditions of any agreement we have with you;
13. to ensure compliance with statutory obligations;
14. to credit reporting bodies;
15. for purposes related to the Company’s research, development and analysis, planning, web site development, security and risk management;
16. where a third party acquires or wishes to acquire an interest in the Company or the business of the Company; or
17. to the extent we are required or authorised by law to do so.

If you do not wish to receive direct marketing communications from us, please contact the Company’s Privacy Officer via the contact details listed below or click the unsubscribe function included in our marketing communications.

 

9. Who we disclose your Personal or Sensitive Information to

 

We may disclose your Personal or Sensitive Information to:

1. third party service providers that we have engaged to provide a service to us in relation to our goods, services, and business operations (for example, payment services, IT, marketing, delivery, installation and other goods or services); and
2. our other ASSA ABLOY group companies (including overseas ones, most commonly, in the United States and countries in the European Economic Area). It is not practical to list all of the relevant countries, given the scope of our operations and changes in our arrangements that occur from time to time, but below we provide more information relating to how we manage disclosure of information outside of Australia and New Zealand, as well as information on how you can request information from us specifically relevant to your arrangements with us.

We only disclose Personal or Sensitive Information to third parties to the extent necessary for them to provide the particular goods and services for which they are engaged to provide or as otherwise set out in this Privacy Policy. As noted above, in some cases we may share your personal information with third parties or other ASSA ABLOY group entities that are located outside of Australia or New Zealand (as applicable). Whenever we do this, we require these parties to take appropriate measures to protect your information and restrict how they can use it. Those parties will usually also be subject to privacy laws in the jurisdictions in which they are located and/or operate. If we propose to transfer Personal or Sensitive Information outside of Australia and New Zealand to a party overseas, and we do not consider legislative or contractual protections are in place to apply protections comparable to those that apply in the place from where the transfer is occurring, we will seek your prior consent to that transfer. If you have provided us with information about another person, you warrant that you are authorised to provide such information on that person’s behalf and that the information is, to the best of your knowledge, current and accurate. Your obligations under privacy laws may also mean that you need to tell that person about the disclosure and let them know that they have a right to access their Personal or Sensitive Information and that we will handle their Personal or Sensitive Information in accordance with this Privacy Policy. Other than as set out in this Privacy Policy, we do not sell or otherwise provide your Personal or Sensitive Information to third parties or make any other use of your Personal or Sensitive Information which is not incidental to your relationship with us.

 

10. Links to other websites

 

Our websites may contain links to other websites. Those links are provided for convenience only- our Privacy Policy does not apply to those websites and any information collected by such third parties is governed by that third party’s privacy practices or policies. We are not responsible or liable for the privacy practices or the content of any third party websites. The use of such websites is at your own risk. Our websites may interface with social networks to allow users access to various social platforms (Facebook, YouTube, Twitter, LinkedIn, etc.). To understand how and what

information is collected and what cookies are used by such third parties, you should check their privacy policies.

 

11. Cookies of ASSA ABLOY company websites (companies listed in Schedule 1 below)

 

We and our service providers may utilise various technologies (including cookies (generally), analytic cookies, targeting, advertising or remarketing cookies, web beacons and pixels, and other types of technologies) (collectively cookies) which assist us in our functions and activities including our dealings with you, for the provision of goods and services and for marketing and remarketing purposes. For example, cookies allow us to monitor traffic patterns and usage statistics, and to identify visitors.

A "cookie" is an electronic information file that is stored and accessed on your computer or device. There are several types of cookies used on our websites which may remain on your computer or device for varying periods of time, including in some instances, permanently, unless you delete them from your computer or device. We may also use cookies in other platforms, including in our emails, newsletters and other electronic communications.

We also use third party service providers (examples of providers we have utilized for this purpose include Google Analytics, Usabilla and Hotjar) to collect and process data and to analyse our visitors' behaviour on an anonymous and aggregate level. This allows us to log information about visits and site visitors for various purposes, including remarketing purposes and in order to improve the user experience of our websites. For more information about how such third party service providers collect and use your data, please access their privacy policies by visiting the service providers’ websites.

To assist in our functions and activities, cookies are also used in our remarketing practices in various instances, including in order to determine who has previously visited or interacted with our websites, used our mobile apps or interacted with our videos. This allows us to advertise online to you through third parties, including Google, who may also use cookies in order to track website activity and show our advertising online across various websites, platforms and devices.

You can opt out of Google Analytics and Google’s use of cookies by searching ‘Google opt out’.

If you do not wish to accept cookies, you should set your computer or other device to not automatically accept cookies from being stored or to inform you whenever a site requests storing a cookie. Previously stored cookies may also be able to be deleted from your computer. However, be aware that some areas or functions of our websites depend on cookies and may not work if you delete or do not accept them.

Please contact us at Privacy.NZ@assaabloy.com for more information about the use of cookies or the full list of our third party service providers.

 

12. Security

 

We take reasonable steps to protect Personal and Sensitive Information from unauthorised access, use, loss, misuse, modification, interference or disclosure. Where your Personal or Sensitive Information is provided to us electronically (including over the internet or via the use of any apps), we cannot ensure or warrant the security of any information you

transmit to us during that transmission process, and you do so at your own risk. Business in Australia and New Zealand are subject to certain requirements to retain information for different periods of time. Accordingly, in addition to holding Personal or Sensitive Information for the period that aligns with the purposes for which it is collected, we may need to retain such information in a secure environment for a longer period to satisfy our legal obligations and for good operational practices. Once the appropriate retention period has elapsed, we will destroy or de-identify such information to the extent practicable and reasonable to do so. We will also destroy or de-identify any Personal or Sensitive Information that we become aware was provided on an unsolicited basis and is not needed for the types of legitimate purposes (or subject to the types of retention obligations) referenced in this Privacy Policy.

 

13. Access to and correction of Personal or Sensitive Information

 

You can contact us via the contact details below to:

• request access to any Personal or Sensitive Information which we hold about you;
• comment on or query our Privacy Policy;
• request a correction or update to your Personal or Sensitive Information;
• make a complaint about our compliance with the APPs or IPPs.

The Company will deal with such a request in accordance with the requirements of the APPs and New Zealand privacy laws. We won’t charge you for making a request to access or correct your personal information. However, we may charge a reasonable access fee to cover our costs of providing the information to you. Where this would apply, we’ll let you know in advance of providing the information.

 

14. Variation

 

This version of our Privacy Policy came into effect on 22nd January 2024. We may need to update it over time but if we do, we will post the updated version on this page.

 

15. Miscellaneous

 

Nothing in this Privacy Policy shall be read or applied so as to exclude, restrict or modify or have the effect of excluding, restricting or modifying any obligation or right implied by law (including the Privacy Act 1988 (Cth) or the Privacy Act 2020 (NZ)), and which by law cannot be excluded, restricted or modified. Headings used in this Privacy Policy are for convenience only and shall be ignored in construing this Privacy Policy.

References to ‘include’ and like words are by way of example only and are without limitation.

References to any document (including this Privacy Policy) are references to that document as varied, amended, consolidated, supplemented, novated or replaced from time to time.

References to any law are references to that law as amended, consolidated, supplemented, or replaced from time to time.

This Privacy Policy shall be governed and construed in accordance with the laws of Australia or New Zealand (as the context requires).

 

16. Contact Details

 

For Australia

Privacy.Au@assaabloy.com

Tel: 1300 562 587

For New Zealand

Privacy.NZ@assaabloy.com

Tel: +64 (0)9 448 9188

 

Schedule 1

 

ASSA ABLOY Australia Pacific Pty Limited

ASSA ABLOY Australia Pty Limited

ASSA ABLOY Door Group Australia Pty Limited

The Denmore Group Pty Limited

Lietzke Australia Pty Limited

Austral Monsoon Building Products Pty Limited

D&D Technologies Pty Limited

D&D Group Pty Limited

ASSA ABLOY New Zealand Limited

Pacific Doors Systems Limited

NZ Fire Doors

General Data Protection Regulation (GDPR)