Privacy Notice

Privacy Notice 

Curries, a division of AADG, Inc. (ASSA ABLOY) (“we,” “us”) is committed to protecting your personal data. In connection with your use of this ASSA ABLOY service. The purpose of this Privacy Notice is to describe how we collect and process the personal data (or Personal Information as per CCPA) that we receive in connection with your use of the website and mobile apps, which will be referred to as “service” in this notice.

This policy applies to ASSA ABLOY owned or operated websites and mobile apps. 

We will collect and process the personal data you provide through our websites and mobile apps.

What personal data will ASSA ABLOY process, and why?

ASSA ABLOY will process your personal data in accordance with the following description. The data we process and collect will principally come from your use of the application required to use the “service.” ASSA ABLOY will process your personal data to provide you with the service and support connected with the service.

We collect and store:

  • When you request information from us: your name, address, email, and/or telephone number, which you submit to obtain information from us.
  • When you order from us: your contact and delivery details, as well as any other information required to verify and fulfill the order. This also includes financial information that you submit to us.
  • When you visit our digital services and websites: your browsing behavior on the site, such as pages visited and the time spent on each page.

 A. ASSA ABLOY will process the personal data set out in this section A to fulfill the contract to provide the service to you:

 

Why do we process this personal data?

What is the legal basis for such processing?

To provide you with the information you request.

Using your personal data in this way is necessary for us to respond to your request, which is our “legitimate interest.”

To set up and manage your account, for example, by sending you password reminders or notifications of changes to your account details.

Using your personal data in this way is necessary for us to provide you with an online account, which is our “legitimate interest.”

To fulfill your order where you have made a purchase from this digital service, to contact you about sales and as a part of our customer relation procedures.

Using your personal data in this way is necessary for us; we are “performing our contractual” obligations where you have placed an order on this digital service.

To keep your payments safe and secure and protect the security of our website.

It is in our “Performance of a contract” to process personal data to keep our customers' payments secure, prevent fraud and protect our digital services from cyber-attacks. In addition we are “legally obligated” to retain this data for government compliance.

To comply with legal requirements to which we are subject, such as tax or financial reporting requirements.

Using your personal data in this way is necessary for us to comply with our “legal obligations.”

 

B. ASSA ABLOY will process the personal data to achieve our legitimate interest in developing and updating our products and services:

Why do we process this personal data?

What is the legal basis for such processing?

To carry out statistical analysis about the use of the website. To better understand how our website is used and make improvements.

It is in our “legitimate interest” to look at this information to understand how our website is being used, manage, and improve it. Since no sensitive personal data will be processed and the processing is limited, we have concluded that our legitimate interest in conducting the improvements and analysis takes precedence over your privacy interest.

To better understand your interests and preferences in order to provide you with an experience that is tailored to those interests and preferences.

It is in our “legitimate interest” to look at the preferences that we derive from your browsing behavior and purchases so that we can personalize content to meet your needs as a customer better, provided this be in line with your marketing choices.

To send you communications about relevant solutions, products, and services which may be of interest, in accordance with your marketing preferences.

We will only send you marketing materials where we have your “consent” or where we have a legitimate interest to keep you updated.

ASSA ABLOY may use information collected from other sources (e.g., Shopify, Google, Facebook) to help us update and analyzed our records to identify new customers. Note: we have no control over how your data is processed (collection, store, or use) by other applications, we advise you to check the privacy policies and cookies policy of any such websites before providing any data. ASSA ABLOY will process your personal data for providing you with the service and support connected with the “service.”

It is in our “legitimate interest” to look at this information to understand how our website is being used, manage, and improve it. Since no sensitive personal data will be processed and the processing is limited, we have concluded that our legitimate interest to conduct the improvements and analysis takes precedence over your privacy interest

Store access usage and store access visitors, including the type of device or browsing you are using.

It is in our “legitimate interest” to look at the preferences that we derive from your browsing behavior and purchases so that we can personalize content to meet your needs as a customer better, provided this be in line with your marketing choices.

 

C. ASSA ABLOY Do not sell or rent your Personal Data, see full disclosure in the following link.  

[Insert link for “Do Not Sell My Personal Information”]

To justify the processing under section B above, ASSA ABLOY has performed a balancing test to ensure that your privacy interests do not outweigh our legitimate interest. Since the processing is limited to non-sensitive data and processed data is aggregated, we have concluded that your privacy interest does not outweigh our legitimate interest. As a data subject, you have a right to obtain information on how we conclude the balancing test in your case.

Transfer of personal data

We may transfer your personal data to the following categories of recipients to the extent necessary to complete the processes stipulated above or if legally required:

  • Government agencies and institutions;
  • Other legal entities within the ASSA ABLOY group; and
  • Our service providers, such as legal counsel or IT hosting providers relevant to the “service.” 
  • To a buyer or a potential future buyer of our business

These third parties may only use your personal data according to our instructions.

International Use

We exercise care in facilitating the transfer of data between your computer or device and our computers or servers (or third party servers which operate and store personal data for the “service”). We have the mechanisms in place to safeguard your personal data after we receive it.

We have our servers and offices in the European Union and the United States; it is possible that during one of our processes, your personal data may be transferred to, stored, or processed in one of these locations. As the data protection, privacy, and other laws of the United States might not be as comprehensive as those in the EU, we take many steps to protect your privacy, we could offer a Data Processing Agreement for EU customers. 

When you use the “service,” you understand and consent to the collection, storage, processing, and transfer of your personal data to our facilities in the European Union, the United States and, the third parties with whom we share it as described in this notice. 

For how long will ASSA ABLOY store your personal data?

ASSA ABLOY stores the personal data as long as it is necessary to fulfill the purpose for which the data has been collected, unless we may, or are obligated by law to store personal data for a longer time. ASSA ABLOY will delete your data when we are no longer required by law to retain it or when it is no longer necessary for the purposes of providing the “service.” Upon termination of the “service,” the data will be:

Type of data stored

How long is it stored?

Contact information you provide, such as your name, email address, region/country, and company name.

Deleted 12 months after becoming inactive or after three email bounces.

Your responses in surveys that you participate in.

Deleted 12 months after the end of the survey period. Aggregate data that cannot be tied to an individual may be stored longer.

Marketing preferences such, as opt-in or opt-out to receive information and newsletters through email.

Indefinitely, as it is a legal requirement to respect your preferences.

Information related to our business relationships, such as data in orders and quotes, requirements that you provide us with, and delivery information.

For the duration of our business relationship and 18 months thereafter. Data may be stored longer when we are legally required to do so.

 

Right to access and rectification

You have the right to request access to the personal data relating to you. This includes the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing. You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete. As soon as we become aware of any inaccurate personal data being processed, we will always correct such personal data as soon as possible and notify you accordingly.

Right to erasure

You may request that your personal data be erased for example in the following situations:

  • If the personal data is no longer necessary for the purposes for which it was collected;  
  • if you object to the processing of personal data where we do not have an overriding legitimate interest; 
  • if the processing is unlawful; or 
  • if the personal data has to be erased to enable us to comply with a legal requirement. 

If you have any questions about your right to erasure, please contact the ASSA ABLOY Divisional DPM (Data Protection Manager). Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground. 

Right to object 

You are entitled to object to our use of your personal data that we base on our legitimate interest. If you object, we will no longer process your personal data unless we can show that we have compelling legitimate grounds for the processing that overrides your interests or rights and freedoms or if we need it to establish, exercise, or defend legal claims.

Right to restriction

You can request us to restrict the processing of your personal data in the following situations: 

  • If the processing is no longer necessary for the purposes for which it was collected or otherwise processed; 
  • if you withdraw your consent for the use of data that we base on your consent;  
  • if you believe the personal data may not be correct; 
  • if you believe that the processing is unlawful; or 
  • if we process your personal data based on our legitimate interest, where we do not have an overriding interest in relation to your privacy interest. 

Right to Data Portability

If you request access to personal data about you that you have provided, and if the personal data is being processed automatically, you may request that the data is provided in a structured, commonly used and machine-readable format and you may also request that the personal data is transferred to another controller, if this is technically possible.

California Privacy

California Civil Code Section 1798.83 allows California residents who have used our “service” to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal data (if any) for direct marketing purposes in the preceding calendar year. If you qualify and which to request this personal data, make a request to Privacy Americas with “California Privacy Rights” as the title of your letter, please mail it to 110 Sargent DR, New Haven CT. 06518.

To request removal, you need to provide specific information that you want to remove, such as the URL for each page where the personal data is located, so that we can find it. We are not required to remove any content, or personal data that: (1) federal or state law requires a third party or us to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or personal data. The removal of your personal data from the “service” does not ensure complete removal of that personal data from our systems or the systems of our service providers.

Our obligations under California law are satisfied as long as we anonymize the personal data or render it invisible to other users and the public; therefore, we are not required to delete the information posted by you.

Tracking of usage statistics

The websites and mobile apps makes use of Google Analytics, an analysis service provided by Google, to help us track usage statistics about visitors to our websites and App on an aggregated level. 

Google Analytics collects information such as how often users visit the websites and mobile apps and their geographical location. ASSA ABLOY uses the information to improve the websites and mobile apps technical performance, to optimize the performance of the websites and mobile apps features, to improve users’ experience of the websites and mobile apps, to better tailor the websites and mobile apps to users’ interests and needs and to make the websites and mobile apps easier to use. 

Google’s possibility to use and share information collected by Google Analytics about your visits to our websites and mobile apps; is restricted by the Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html). For information about how Google uses your Data when you use the websites and mobile apps, visit https://www.google.com/intl/en/policies/privacy/partners/. 

By installing the websites and mobile apps, you consent to Google Analytics collection and processing of your Data. For information about how to withdraw your consent, visit http://tools.google.com/dlpage/gaoptout

With our websites and mobile apps, we could collect some information automatically using various mechanisms, including but not limited to cookies and pixels. This collection may include but is not limited to the personal data described on “What personal data will ASSA ABLOY process and why?” section. We collect this (non-identifying information) to help diagnose problems, to administer the “service,” to help identify you and to gather broad demographic information. 

A “cookie” is a text file, which stores on a computer for record-keeping purposes. You can find how we use cookies in our cookies policy. You may set your browser to attempt to reject cookies, and you may be able to use the “service.” Please note that some features of the “service” may not be available if your browser does not accept cookies. 

“Pixels” are small graphics with unique identifiers, which use is to track movements of web users. Different from cookies, pixels are small graphics that could be the size of the period at the end of the sentence, which are embedded invisibly on web pages. It is possible that our third-party analytics providers will place pixels on the Site that track other websites you visit, before and after your visit. Our third-party analytics providers may use information obtained from pixels. ASSA ABLOY does not control the use of pixels by third parties.

As we track website and apps usage information as described above, your selection of the DO NOT TRACK option in your browser may not affect our collection of data. The only way we know to completely “opt-out” of the collection of information through cookies or other tracking technologies is to delete and disable cookies and other tracking/recording tools. 

Some of our websites and apps may contain links to third-party websites, including social media such as Facebook, LinkedIn, Instagram or Twitter. We are not responsible for the privacy practices or content of any of these linked sites. Linked sites may collect personal data from you that is not subject to our control. The personal data collection practices of Linked Sites will be governed by that site’s privacy policy.

We take measures to protect all personal data transferred to a third party, or other countries, in accordance with applicable data protection laws and, as stated above. No transmission of data over the Internet can be 100% secure. There is always a risk that information collected by and displayed on the “service” may be compromised or accessed, notwithstanding the steps we take to secure your personal data. For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the “service” may abuse or misuse your personal data. Accordingly, you agree that you are providing such personal data at your own risk.

Children’s Privacy

The “service” is Not for or Directed to Children nor anyone under 18 years old, we do not intend to and will not knowingly collect any personal data from children under the age of 18. If we learn that we have collected personal data from an under age of 18 children, we will remove that personal data immediately and delete it from our servers (if not required or resulted by applicable law and this Privacy Notice). If you believe content from an under 18 years child has been posted in our “service,” please notify us by contacting us at  Privacy.Americas@assaabloy.com 

California Minors. The “service” is not intended for anyone under the age of 18. If you qualify as California resident, under 18 years old and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at Privacy.Americas@assaabloy.com

Changes and Updates to this Privacy Notice

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 allow number of times, under applicable law guidance. 

Contact Information and Questions

ASSA ABLOY is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to “Attn.: ASSA ABLOY AMERICAS Data Protection Manager” at ASSA ABLOY AMERICAS 110 Sargent DR. New Haven, CT. 06511 or Privacy.Americas@assaabloy.com