Effective Date: 21 June 2021

  1. Data Protection

Allegion is committed to (i) protecting your personal information and (ii) being transparent about how we use the personal information we collect from you.  This Privacy Statement describes the personal information that Allegion Plc., its subsidiaries, and affiliates (collectively “Allegion”) collect from you, as well as our use, disclosure, and transfer of that information. In this Privacy Statement, “we,” “us,” and “our,” refer collectively to Allegion.

This Privacy Statement applies to personal information that we collect from you through Allegion websites, portals, web and mobile applications (individually, an “Application” and collectively, the “Applications”) in which this Privacy Statement is included or is otherwise incorporated by reference.  For a listing of the Allegion entities that control or process your personal information, please contact us at dataprivacy@allegion.com.

  1. Information We Collect

We collect information directly from you and automatically through your use of the Applications, in certain cases to access functionality of the Applications or fully take advantage of the Applications’ offerings (e.g. access to informational, marketing, or collaboration-related content).

We collect information directly from you when you use our Applications to:

  • Register or update your profile or account information
  • Apply for a job with us or register to our talent management platform
  • Request information from us or sign up for a newsletter or download content
  • Place an order or pay an invoice
  • Complete a survey
  • Contact us

The legal basis for such collection is either your consent, our legitimate interest, or other lawful basis as specified under the applicable law depending on the specific case.  To the extent permitted by law or with your consent, we may combine any or all of the information that we collect about you from various sources.

We automatically collect some information when you use our Applications.  This information includes, but is not limited to:

  • domain name
  • device type and device browser type and/or operating system
  • search terms
  • geolocation
  • Internet protocol (“IP”) address
  • date, time, and duration on the Applications
  • engagement, usage, and interactions with the Applications
  • referring URL, search engine, or web page that led you to our Applications

The legal basis for such collection is our legitimate interest of providing you with the requested information and responding to you, as well as ensuring the stability and security of the Applications, which is technically necessary for us to provide you with the Applications.  It should be appreciated that certain Applications will have a separate privacy policy.  Accordingly, where applicable, please refer to that privacy policy associated with the respective Application for information about the data automatically collected when you use one of those Applications.

Some of the above information collected by us may be considered “sensitive personal information” under applicable law.  We collect and use it to the extent necessary for the purposes as described above.

We may obtain certain information collected by third-party service providers who may use cookies, pixel tags, or similar tracking technologies to capture information about your interactions with the Applications, in addition to information about sites you have visited.  Please see our Cookies Policy for additional information about our use of cookies, your ability to accept/decline cookies, and related information.

  1. Minors

Allegion considers those persons under the age of 18 or otherwise as required under applicable law to be a minor.  If you are under the age of 18, please do not submit any personal data. The Applications are neither designed for nor targeted to minors, and we do not knowingly process the personal information of minors. We disclaim any and all liability for any personal data submitted in contravention of this clause to the extent permitted by relevant laws and without limiting any other provisions of this Privacy Statement.  If you believe a minor has impermissibly provided us with their personal information, please contact us via email at dataprivacy@allegion.com so that we can identify and delete their information.

  1. Use of Your Personal Information

Allegion uses personal information to provide you our Applications, products, and services, process your transactions, to communicate with you, for security and fraud prevention, and to comply with applicable laws.  We may also use personal data for other purposes with your consent and only when we have a valid legal basis to do so.  Depending on the specific use case, Allegion may rely on your consent, or the fact that the processing is necessary to fulfil a contract with you, to protect your vital interests or those of other persons, or to comply with law.  We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations

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 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 Privacy Statement and other applicable 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 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 this Privacy Statement.
  • 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. Where required by applicable law, we will require the recipient of your personal information to comply with this Privacy Statement and obtain your consent if the recipient will use your personal information purposes that are not described in this Privacy Statement.
  1. Disclosure/Recipients of Your Information

Allegion may share your information, including personal data, with service providers who act on our behalf, our partners, or others as follows:

  • Other users of our Applications. Any information that you post to discussion forums or other public portions of our Applications, may be available to all other users of our 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 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 this Privacy Statement. Allegion does not and will not sell personal information to third parties. Allegion does permit third parties to collect personal information through the Applications and shares personal information with third parties for the business purposes described herein.
  • Aggregate and anonymized information. We may disclose aggregate or anonymised information about you with third parties for marketing, advertising, research, or similar purposes, to the extent permitted by applicable law.
  • You have consented. We may also disclose the personal information we collect from you where you may have consented to the disclosure.
  1. Cookies and Tracking Mechanisms

We and our service providers use cookies, tracking pixels, and other tracking mechanisms to track information about your use of our Applications and the applications and services available through our Applications.  You may disable certain tracking by disabling cookies in your web browser or by updating your consent preferences in the Cookie Consent Management Center as described in the Cookie Policy.  Please see our Cookie Policy for additional information about our use of cookies, your ability to accept/decline cookies, and related information.  We or our service providers may combine this information with other information we have received about you.

  1. 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. To learn more about Do Not Track signals, please see this resource.

  1. Third-Party Links

Our Applications may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Statement, 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.

  1. 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 Applications, we do not guarantee that the Applications or any products or services are impervious to attack or that any use of the 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.

  1. 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 laws, unless you are hired, in which case some of this information will be stored in your employment record.

  1. Your Rights and Choices

When it comes to your personal data, subject to the requirements under applicable law, you may have the following rights:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object to processing

If you believe that the processing of your personal data violates legal requirements, you may also have the right to lodge a complaint with a competent data protection supervisory authority, depending on applicable laws.

If the personal data has been collected in the EU and transferred outside of the EU, you additionally have the right to request details of the safeguards relied upon by us in relation to the transfer.

Your choices. You can always choose not to provide information, even though it might be needed to take advantage of certain functionality or services.  You can also choose to withdraw any previously given consent with regard to our processing of your personal data.  However, it is important to keep in mind that in certain cases we will be unable to process 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 or otherwise withdraw your consent, you must send your request to the following e-mail address: dataprivacy@allegion.com.

Opting out of cookies. Please see our “Cookies and Tracking Mechanisms” section of this Privacy Statement and our Cookie Policy for more information about blocking or disabling cookies.

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. This opt-in may be obtained via explicit consent when submitting a form, attendance or interactions at trade shows, and during in-person market research, to name a few examples.  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.

  1. Exercising Your Rights

You can submit a Data Subject Right’s request by clicking the “Submit DSR” button located at the end of this Privacy Policy and submitting the associated form, or sending us an email with your request to dataprivacy@allegion.com.  Once we receive your request, we will contact you to verify your identity (e.g., via email address you previously provided to us) and country of residence.  You may be entitled, in accordance with applicable laws, 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 dataprivacy@allegion.com.  Allegion will respond to your requests within a reasonable amount of time as may be defined by applicable law, 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.  It should be appreciated that there are some circumstances in which we are neither required to give you access to nor delete 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.

United States

California residents may additionally submit requests to exercise their rights under the California Consumer Privacy Act by calling us at 1-877-671-7011.  California residents may also 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.  Please allow up to thirty (30) days for a response.

Mexico

Mexican residents may 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), only when the Mexican Federal Law on Protection of Personal Data Held by Private Parties applies.

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.

  1. 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, 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 than to perform the intended function.

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.

Personal data of EU residents will only be transmitted outside the EU or the European Economic Area if the other conditions for such transmission under the GDPR are fulfilled (appropriate safeguards to protect your personal data, e.g., signing of EU standard contractual clauses with the service provider(s) pursuant to Art. 46 (2) c) GDPR). Please contact us to request a copy of our appropriate safeguards.

Personal data of Chinese citizens will only be transmitted outside of China if Allegion has fulfilled its obligations under Chinese laws (e.g., signing of a standard contract with the recipients outside of China). Allegion will also take measures to ensure that the recipients of your personal data will provide the same level of protection as required under Chinese laws.

  1. Data Controllers

You can find the most updated list of current data controllers by Allegion brand and entity by clicking here.

  1. Changes to this Policy

We may change this Privacy Statement from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Statement on the Applications. If we make any changes to this Privacy Statement that materially affects 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 Applications or e-mailing you. Your continued use of our Applications or the related applications or services or your provision of further information further to the change in this Privacy Statement constitutes your acceptance of our revised Privacy Statement. You can obtain a copy of our current Privacy Statement by contacting us using the information in the “Contact Us” section.

  1. Contact Us

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 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: dataprivacy@allegion.com.  Otherwise, you are encouraged to contact us at dataprivacy@allegion.com if you have any questions or concerns about this Privacy Statement, the personal data we have about you, you require assistance in managing your choices, or you have other data privacy related questions, comments, or complaints regarding our privacy practices. The messages you send to us will be transferred to and reviewed in the United States.