Effective Date: 20 May 2020
1. Table of Contents
2. Information We Collect
We collect information directly from you and automatically through your use of the Allegion Applications. To the extent permitted by law or with your consent, we may combine all of the information that we collect about you from various sources.
Information we collect directly from you. We collect information from you when you register to access the Allegion Applications, populate or update your account information (including your user profile) on the Allegion Applications, apply for a job with us or register to our talent management platform, request information from us, contact us, or otherwise use our products and services through the Allegion Applications. The information we collect varies depending on your interaction with us, and may include, but is not limited to, identifiers like your name, mailing address, telephone numbers, fax number, and e-mail address, as well as commercial information like billing address, transaction and payment information (including financial account numbers or credit or debit card numbers), and purchase history. We also collect any other information that you choose to provide to us (e.g., registration information if you register for one of our training programs or subscribe to our My Allegion News newsletter, such as username and password; drawings or design content if you interact with one of our product or specification collaboration applications; information you provide while participating in discussion forums; or professional or employment-related information like job function or information you provide when you apply for a job with us or register to receive information about career opportunities at Allegion) through the Allegion Applications.
If you choose not to provide us with any personal data you may not be able to take advantage of the Allegion Applications’ offerings (e.g. access to informational, marketing or collaboration-related content).
Information we collect when you visit our Allegion Applications. When you visit our Allegion Applications, the information that we automatically collect includes, but is not limited to: domain name; device and browser type and operating system; search terms and other usage information (including web scrolling, browsing, and click data to determine what webpages are viewed and links are clicked); geolocation; Internet protocol (“IP”) address; the date, time, and length on the Allegion Applications or using our applications or services; and the referring URL, search engine, or the web page that led you to our Allegion Applications. The legal basis for such processing is our legitimate interest to ensure the stability and security of the Allegion Applications, which is technically necessary for us to provide you with these services.
Information we collect through cookies when you visit our Allegion Applications: With regard to personal information we collect through cookies, web beacons, and other technologies when you visit our Allegion Applications or use our related services we refer to the section “Cookies and Tracking Mechanisms” below.
To the extent permitted by law or with your consent, we may combine this information with other information that we have collected about you, including from our vendors who help us provide services to you. Please see “Cookies and Tracking Mechanisms” below for more information.
4. Use of Your Information (Purposes)
We use your information, including your personal data, for the following purposes:
· To provide our products and services to you. We use your information to provide our applications, products and services to you; to take, verify, process, and deliver orders and returns; for warranty, technical support, or other similar purposes; and to service customer accounts.
· For vendor management purposes. We use your information to establish and maintain vendor accounts, provision the requested products and services, and take other actions in furtherance of vendor management. The information that we collect from our vendors is used also for the purposes set forth in this section.
· Customer service. We use your information for customer service purposes, including for warranty, technical support, or other similar purposes; to generate, update and report on order status and history; to respond to your inquiries; and for other purposes for which you contact us.
· Communication. We use your information to communicate with you, including to respond to requests for assistance, inquiries or complaints. Subject to applicable law, we may communicate with you in a variety of ways, including by postal mail, e-mail, telephone, and/or text message.
· Administration. We use your information for administrative purposes, including to manage our inventory; to help us better understand access to and use of our Allegion Applications; to provide information and reports to investors, prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, users, vendors, us, and the general public; to enforce this Policy, our Terms and other policies.
· Recruitment and talent management. We use your information to administer and assess your application for a position at Allegion. With your consent, we may send you communications about career opportunities or use your information for recruitment events.
· Research and development. We use your information for research and development purposes, including to improve our Allegion Applications, applications, products, services, and customer experience; to understand our customer and user demographics; and for other research and analytical purposes, including sales history analytics.
· Legal compliance. We use your information to comply with applicable legal obligations and assist government and law enforcement agencies or regulators, in order to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena or other lawful governmental request or where we are otherwise required or authorized by law to do so.
· To protect us and others. We use your information where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms or this Policy.
· Marketing. We use your information where required by law, to the extent permitted by law, or with your consent (where required by law) for marketing and promotional purposes, including through e-mail. For example, we may use your information, such as an e-mail address, to send news and newsletters, special offers and promotions, or to otherwise contact you about products, services or information we think may interest you. We also may use your information to assist us in advertising our services on third-party websites or through other venues.
· Business transfers. We may disclose your information in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
The legal basis for such processing is - depending on the specific case - either your consent or our legitimate interest.
5. Disclosure/Recipients of Your Information
We may disclose your information, including personal data, as follows:
· Users of our Allegion Applications. Any information that you post to discussion forums or other public portions of our Allegion Applications, may be available to all other users of our Allegion Applications and may be publicly available upon posting.
· Affiliates and subsidiaries. We may disclose your information to any current or future affiliates or subsidiaries, for the purposes described above under use of personal data. Subject to legal requirements, we may, for example, share your information with one of our U.S. entities for storage purposes.
· Service providers. We may disclose personal data to third-party vendors, service providers, contractors or agents to enable them to perform functions on our behalf. These service providers may, for example, help us administer our Allegion Applications or provide informational or marketing content. Please see "International Transfers and Offshore Storage of Personal Data" section below for more details of those countries in which (or to which) we may use, disclose, process, transfer or store your personal data.
· Other non-affiliated third parties. We may disclose your information to non-affiliated third parties, such as wholesalers, distributors, promotional partners, service providers and others with whom we have marketing or other relationships for their own marketing purposes. To the extent permitted by law or with your consent, those third parties may use your personal data for their own marketing purposes, such as to market products and services that they believe would be of interest to you. In addition, we may disclose your information to third parties in connection with business transfers, in response to legal processes and to protect us and others as further described in the section 4 (Use of Your Information (Purposes)) above. Allegion does not and will not sell personal information to third parties. Allegion does permit third parties to collect personal information through the Allegion Applications and shares personal information with third parties for the business purposes described above.
· Aggregate and anonymised information. We may disclose aggregate or anonymised information about you with third parties for marketing, advertising, research or similar purposes.
· You have consented. We may also disclose the personal information we collect from you where you may have consented to the disclosure.
6. Cookies and Tracking Mechanisms
· Where they are essential to make our Allegion Applications work. The legal basis for the use of these Cookies is our legitimate interest in ensuring that our Allegion Applications are set up in a way that provides basic functions for our users. This helps us to promote our Allegion Applications and to remain competitive.
· To compile anonymous, aggregated statistics that help us to understand how users use our Allegion Applications and to help us improve the structure and functioning of our Allegion Applications. The processing of personal information through these Cookies is subject to your consent.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags) in connection with our Allegion Applications to track the activities of users of our Allegion Applications, help us manage content, and compile statistics about usage of our Allegion Applications. We or our service providers may also use clear GIFs in HTML e-mails to our users, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. The legal basis for the use of these technologies is your consent.
7. Do Not Track Disclosure
Currently, our systems do not recognize browser “do-not-track” requests. You may disable certain tracking as discussed above in our “Cookies and Tracking Mechanisms” section (e.g., by disabling cookies). To learn more about do-not-track signals, please see this resource.
8. Third-Party Links
Our Allegion Applications may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the privacy, security and information practices of such third-party websites.
9. International Transfers and Offshore Storage of Personal Data
We may use, disclose, process, transfer or store information, including personal data, outside the country in which it was collected, such as to the United States and other countries, which may not guarantee the same level of protection for personal data as the country in which you reside.
Additionally, there are situations when personal data is transmitted to third-party service providers (in the United States and/or other countries, including countries in which Allegion operates or has offices) to provide services for Allegion, such as payment processing and web hosting and other services required by law. Allegion uses third-party service providers to process personal data for service-related and administrative purposes. Such service providers are located in the United States and other locations where Allegion does business. When Allegion retains another company to perform a function of this nature, such third party will be required to protect the personal data and will not be authorized to use the personal data for any other purpose.
The countries that we may use, disclose, process, transfer or store your information in are likely to be Australia, Austria, Belgium, Canada, Chile, China, Colombia, Denmark, France, Germany, Hong Kong, India, Ireland, Italy, Malaysia, Mexico, Netherlands, New Zealand, Panama, Poland, Russia, Singapore, South Korea, Spain, Sweden, Switzerland, Turkey, UAE, the United Kingdom and the United States.
With regard to residents in the EU: your personal data will only be transmitted outside the EU or the European Economic Area if the other conditions for such transmission under the GDPR are fulfilled (e.g., signing of EU standard contractual clauses with the service provider(s) pursuant to Art. 46 (2) c) GDPR).
10. Security of Personal Data
We may store your personal data in electronic format. We have implemented reasonable measures to protect the personal data we collect from damage, misuse, interference, loss, alteration, destruction, unauthorized or accidental use, modification, disclosure, access or processing, and other unlawful forms of processing data. However, please be aware no data security measures can guarantee 100% security. While we monitor and maintain the security of the Allegion Applications, we do not guarantee that the Allegion Applications or any products or services are impervious to attack or that any use of the Allegion Applications or any products or services will be uninterrupted or secure. In addition, information that you transmit over the Internet, including through e-mail or SMS message, is not secured by us and is inherently vulnerable to attack or interception.
11. Retention of Personal Data
We will retain your personal data for as long as we have a reasonable legal or commercial need for it, after which time we will destroy it through currently available secure destruction means. Personal data collected for recruitment purposes will be retained for a reasonable period of time in accordance with applicable law, unless you are hired in which case some of this information will be stored in your employment record.
12. Your Rights and Choices
· Your rights. You provide your personal data to us voluntarily. Depending on your jurisdiction, you may have the right, at any time, to learn whether Allegion processes personal data about you, to request information as to your personal data being processed, to access personal data that Allegion holds about you; to learn the purpose of the processing and to check whether the data is being processed in accordance with the original purpose, to request that we restrict the use of your personal data or stop using or disclosing your personal data; to request that we update, amend, or delete your personal data; to know the third parties to whom your personal data has been transferred, request third parties to be informed of any rectification, update, deletion, object to the occurrence of any result that is to your detriment by means of analysis of personal data exclusively through automated systems, request portability of your personal data or compensation for damages due to unlawful processing of your personal data and to withdraw any previously given consent with regard to your personal data; using the contact information below. Residents in the EU have the right to object to the processing of personal data, which we base on our legitimate interest, for reasons arising from your particular situation. Further information on our data processing operations and the legal basis on which they are based can be found in section 4 above. If you file an objection, we will no longer process your personal data, unless we can prove compelling reasons for the processing worthy of protection which outweigh your interests, rights and freedoms, or the processing serves the enforcement, exercise or defence of legal claims. You may make such requests by submitting a request here. Once we receive your request, we will contact you to verify your request. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please e-mail firstname.lastname@example.org. Allegion will respond to your requests within a reasonable amount of time, unless you are notified otherwise by us in writing. There is no charge for requesting access to your personal data but we may ask you to meet reasonable costs in providing you with access, for example photocopying or postage costs. There are some circumstances in which we are not required to give you access to your personal data. We will take all reasonable steps to ensure that the personal data we hold about you remains accurate, up to date and complete.
· Your choices. You can always choose not to provide information, even though it might be needed to take advantage of certain services.
· Opting in to marketing communications. We may ask you to opt-in to receive marketing communications if your opt-in consent is required under applicable law. If your opt-in consent is not required under applicable law, we will not seek your opt-in consent, but you will have the right to opt-out as set forth below.
· Opting out of marketing communications. We may send you promotional e-mail messages if you request to receive information from us. You may request to stop receiving promotional e-mail messages by following the link contained in the e-mail itself. Please note that if you opt out of receiving e-mail marketing communications from us, we may continue to communicate with you for other purposes (e.g., to respond to your enquiries or for service-related purposes). You may otherwise opt out of receiving marketing communications from us by contacting us at the mailing addresses set forth in the “Contact Us” section below.
· Request of ARCO rights (applicable only when the Mexican Federal Law on Protection of Personal Data Held by Private Parties applies).
As long as your relationship with us exists, you have the responsibility to make sure that all your data is up to date. Please be advised that in order to exercise the ARCO rights (Access, Rectification, Cancellation & Opposition) set forth in the Mexican Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares), you may contact, at any time, the privacy officer to request information regarding the treatment that is given to your data at the following email address: email@example.com.
In the event that you exercise an ARCO right, you must submit a request, which must contain at least the following information: (i) full name and e-mail or domicile to inform you the answer to your request; (ii) the documents evidencing your identity or, as the case may be, the legal representation; (iii) a clear description of the personal data respect to which you seek to exercise any of the above mentioned rights; and (iv) any other element or document that facilitates the location of the personal data. Your request will be answered within the period permitted by law and we will inform you if the same proceeds through the e-mail or address that you have provided us for these purposes.
We will inform you if your request proceeds by e-mail or in writing within the following 20 (twenty) business days, but in case it is necessary additional information may be requested. In case it proceeds, we will answer your request within a term of 15 (fifteen) business days after the previous term.
You may revoke the consent that, as the case may be, you granted us for the handling of your personal data. However, it is important that you keep in mind that not in all the cases we will be able to answer your request or immediately conclude the use thereof as it is possible that due to some legal obligation we will be required to continue handling your personal data. To revoke your consent, you must send your request to the following e-mail address: firstname.lastname@example.org.
13. Special Information for California Consumers
California residents may request a list of certain third parties to which we have disclosed certain personal data for their own marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us using the information in the “Contact Us” section below. Please allow up to thirty (30) days for a response.
14. Changes to this Policy
We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Allegion Applications. If we make any changes to this Policy that materially affect our practices with regard to the personal data we have previously collected about you, we will endeavour to provide you with notice in advance of such change by highlighting the change on the Allegion Applications or e-mailing you. Your continued use of our Allegion Applications or the related applications or services or your provision of further information further to the change in this Policy constitutes your acceptance of our revised Policy. You can obtain a copy of our current Policy by contacting us.
15. Contact Us
Please contact us at email@example.com if you have any questions or concerns about this Policy, the personal data we have about you, require assistance in managing your choices, or have other questions, comments or complaints regarding our privacy practices. The messages you send to us will be transferred to and reviewed in the United States. California residents may submit requests to exercise their rights under the California Consumer Privacy Act by using this web form or calling us at 1-877-671-7011.
If your personal data is subject to the purview of the Office of the Australian Information Commissioner, and if you are still concerned about the way in which any privacy issue has been handled, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available. If you are still concerned about the way in which any privacy issue has been handled, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
Additional Rights (from 25 May 2018)
As of 25 May 2018, with regards to personal data subject to the General Data Protection Regulation of the European Union, you also have the following rights:
· Data portability - to the extent that we are relying upon the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to the Allegion in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
· Right to restriction of processing - you have the right to restrict our processing of your personal data where:
o you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
o the processing is unlawful, but you do not want us to erase the data;
o we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
o you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether the Allegion has compelling legitimate grounds to continue processing.
Where personal data is subjected to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
· Right to object to processing justified on legitimate interest grounds - to the extent that we are relying upon legitimate interest to process data, then you have the right to object to such processing, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Normally, where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the processing of your personal data infringes the European Union's General Data Protection Regulation.
For further information regarding your rights, or to exercise any of your rights, please contact firstname.lastname@example.org.