Privacy Notice - Yale Beta Tester Community

This is the Yale beta test participants privacy notice. Yale is committed to protecting your personal data. This privacy notice describes:

• the types of personal data we collect from you when you participate in one of our testing programmes;
• how we use that information and why;
• who we share it with and where;
• how long we store it for;
• your rights, including how you can contact us if you have additional questions about the processing of your personal data; and
• how we can make changes to this notice

This notice explains how we will process your personal data when you participate in a beta test via the Centrercode testing platform.

Yale may also process your personal data in order for you to use and test a product. For example, if you are required to register an account for an app needed to operate a smart device. For more information about how Yale may process your personal data when you use a product or service as part of a test, please refer to the privacy notice for that product or service. The notice will be provided to you at the point you are asked to provide your personal data, if required.

Yale is a brand owned by the ASSA ABLOY Group. Security & Risk Communications Ltd, registration number 417550, of Parkway Business Centre, Ballymount, Dublin 24, which is the “data controller” and is responsible for the processing of your personal data. Security & Risk Communications Ltd is part of the ASSA ABLOY Group of companies.

When you participate in a beta test, we collect and store:

• Your name, address, email address to contact you about the test requirements and dispatch (and potentially install) products for testing where required.

In order to ensure we recruit testers which meet the needs of our test, we will conduct a survey to understand more about your property and potential use of our products, such as:

• Date of birth (you have to be over 18 to participate)
• Mobile phone platform
• Mobile phone model
• Operating system of the mobile phone
• Yale product account (email or phone number)
• Wi-Fi configuration (type of router, distance from product, etc.)
• Existing Yale products (smart locks, alarm systems, keypads etc.)
• Serial number of the Yale product(s)
• Firmware version of the Yale product(s)
• Details about your family, residents of your property and potential users of a product
• Details of how you may use a product e.g. times it is used, circumstances
• Type of property (detached, semi-detached, flat, gardens, etc.)
• Type of walls in the property (concrete, wood, etc.)
• Type of garage or gate doors (sectional, swing, etc.)
• Type of doors (metal, wood, etc.)

This list is not exhaustive and depending on the nature of the test we may ask for other relevant information to help us understand the environment in which the product will be operated and tested.

Data created as part of the testing process, such as how you may use a product and the feedback you provide to us during any subsequent test surveys. This may include:

• Photographs of the installed Yale product(s)
• Videos of the Yale product(s) being used
• Screenshots of mobile phone screens
• Videos of mobile phones being used
• Survey responses

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

• To organisations of the ASSA ABLOY Group  or third parties which support in the development of Yale products.
• To other organisations of the ASSA ABLOY Group or third parties which support Yale to provide the relevant product you are testing, if applicable. For example, if you are required to download an app in order to use and test a product. For more information about how your data will be shared in this way, view the relevant privacy notice for that product. This will be presented to you at the point you are asked to create an account for that product.
• Data will be shared between Yale and our beta testing community via Centercode, our testing platform.
• When required by law; and/or
• To a buyer or a potential future buyer of our business.

Some recipients are located in countries outside the UK or EU/European Economic Area (EEA). As in some cases these countries have a lower level of protection than that within the UK or EU/EEA, when transferring personal data to countries outside of the UK or EU/EEA we use standard contractual clauses approved by the European Commission and the Information Commissioner’s Office 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 countries, in accordance with applicable data protection laws and as stated above.

We store personal data for as long as necessary to fulfil the purpose for which the data has been collected, and in accordance with our internal record retention schedule. This means that we delete your personal data when such data is no longer necessary to process a request or to manage our relationship. Statistics which have been anonymised may be saved for longer.

In relation to the personal data that we hold about you, you have the right to:

• Request a copy of your personal data from our records;
• Ask that we correct or erase your personal data (though this may mean that we cannot process requests or orders, or that your account expires);
• Ask us to stop processing your personal data (for example as regards the use of the data to improve our website), 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, process an order, or manage your account or our relationship in a machine-readable format, which you are entitled to transfer to another data controller; and
• Withdraw your consent to us processing your data for marketing purposes at any time.

Requests to exercise your rights should be addressed to privacyuk@assaabloy.com

If you have a complaint regarding our processing of your personal data you are entitled to report this to the ICO (Information Commissioner’s Office) at ico.org.uk if you are a UK resident or to the supervisory authority where you live or work if you are an EU resident, a list of which can be found at ec.europa.eu.

We may update this privacy notice from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes (including when they will take effect). Your continued use of the website after any such updates takes effect will constitute acceptance of those changes. If you do not accept any updates to this privacy notice, you should stop using this website.