Privacy Notice for the HKC App and SecureComm Service

This notice relates to the processing of personal data when using the HKC SecureComm Services (“Services”), including use of the HKC SecureComm App (“App”) and the HKC website and portal. Security & Risk Communications Limited, a company incorporated in Ireland with registered number 417550 having its registered office at Parkway Business Centre, Ballymount, Dublin 24, provides the Services. Security and Risk Communications Limited is part of the ASSA ABLOY group of companies.

If you pay a subscription fee directly to Security & Risk Communications Limited in order to use the Services, Security & Risk Communications Limited are responsible for the processing and are the Data Controller.

If you pay a subscription to an alarm system installer in order to use the Services, the alarm system installer is responsible for the processing and is the Data Controller. Security & Risk Communications Limited are acting as a Data Processor of the alarm system installer.

This notice is directed to customers whose personal data is processed by Security & Risk Communications Limited as a Data Controller, however the notice also explains how Security& Risk Communications Limited will process the personal data of alarm system installer’s customers.

We are committed to protecting your personal data in connection with your use of the Services. The purpose of this Privacy Notice is to describe how we collect and process the personal data that we receive in connection with your use of the Services.

This privacy notice describes:

- What personal data we may collect?

- How and why we will use your personal data?

- Who and where is your personal data transferred to?

- How long will we store your personal data?

- Your rights

- How can we make changes to this notice?

- Contact us

What personal data we may collect?

Personal Data We Require for Use of the Services.

When you register to use the Services, we require you to establish an account and collect and store the following: Your name, address, email address, telephone number, Installation ID and bank details and billing address if you pay your subscription for the Services directly to us.

Personal Data collected based on your use of the Services.

We collect personal data that you may provide about yourself, such as site(s) name and Installation ID, as well as personal data about authorised users who have access to use the Services, such as other family members. For example, the usage data for an authorised user who also uses the app on their own device to control the same site(s).

If you use a PIR camera, we will also collect recordings captured via cameras. These recordings are stored securely and are encrypted, so only users with valid credentials can access them.

Personal Data we automatically collect.

We gather the following information for purposes of providing the Services when you download the App and/or access the Services: usage data about how and when you interact with the Services, system status (e.g. set and unset history, alarm activation history, fault history) and a log of changes to the status including who made the change. We also collect the serial number of the app installation.

Personal Data we receive when you use third party products and services.

If you use Dahua CCTV products and choose to integrate functionality provided by Dahua in order to display CCTV images via the App, Dahua will allow access to their services in order to display the images. For more information about how Dahua may process your personal data to enable this functionality, please view the Dahua privacy notice.

How and why we will use your personal data?

Why do we process this personal data?	What is the legal basis for such processing?
To provide you with the service you requested when using the product. This may include identifying / authenticating you when you use the Services, providing any features and functionality of the Services and the products that you elect to use, maintenance which includes software updates, and communicating with you specific to the Services.	Using your personal data in this way is necessary for us to respond to your request. We are performing our contractual obligations under the agreement we have with you to provide the services you have requested. We are unable to provide the services without processing your personal data.
To take subscription payments for your use of the Services.	In order to meet our contractual obligations to provide the Services.
To comply with legal requirements to which we are subject, such as tax, accounting/financial reporting requirements, mandatory disclosures and/or law enforcement.	Using your personal data in this way is necessary for us to comply with our legal obligations.

Who and where is your personal data transferred to?

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

- To organisations of the ASSA ABLOY Group, whether or not going to market as ASSA

ABLOY, that market, sell and support our solutions in your country.

- To third parties who provide customer support services connected to this product or its functions, but only to the extent necessary to provide these services, for example, to a third-party data centre who may store your personal data on our behalf, or to an Alarm Receiving Centre to manage notifications on your behalf and at your request.

- When required by law, including to government agencies and institutions, where legally required.

- To a buyer or a potential future buyer of our business.

We do not sell or rent your personal data to third parties.

In the event that we transfer your personal data to countries outside the EU/EEA we use standard contractual clauses approved by the European Commission 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.

For how long will we store your personal data?

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 your account or our client relationship. Statistics which have been anonymised may be saved for longer.

Your rights

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 that your account expires);

- Ask us to stop processing your personal data (for example as regards the use of the data to improve our product), 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, 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.

We may not accept a request to erase your personal data where we require it to comply with a legal obligation or in relation to a legal claim.

For information about how to exercise your rights, see Contact Us below.

If you are a customer of an alarm system installer, you must direct your request to the alarm system installer, as the Data Controller.

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) if you are a UK resident at https://ico.org.uk/concerns or to the Irish Data Protection Commission if you are an Irish resident at https://forms.dataprotection.ie/contact.

Version 6 2022

How can we make changes to this privacy notice?

We may update this privacy notice from time to time in response to changing legal, regulatory or operational requirements. If we make any material changes to this Privacy Notice, we will notify you by placing a prominent notice on our website or in the app. Your continued use of the product 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 the Services.

Contact Us

If you have any questions about this Privacy Notice, or you would like to exercise any of your rights, please send an email to privacyuk@assaabloy.com.

Legal Notice

HKC App Services Terms and Conditions

Important note: Please read carefully all the terms and conditions of this agreement before you use HKC App services. Once you register and log in, you are confirming acceptance of all terms and conditions. The Privacy Notice informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the App. By using the App, you agree to the collection and use of information in accordance with the Privacy Notice.

Service Regulations

When using HKC App services, the user must comply with the following principles.

1) Abide by the relevant regulations and policies of your country;

2) Comply with all web service network agreements, terms and conditions;

3) Login and use only through the HKC App;

4) Do not use the service for any illegal activity, invasion of privacy or slander purposes;

App Upgrades

HKC reserves the right to upgrade and make adjustments at any time. App upgrades may require a relevant upgrade on the users’ equipment to the relevant operating system in order to access new functionality. HKC cannot guarantee support for old operating systems indefinitely. In addition, HKC retains the right to change or limit some of the functions on the App. The user accepts this and the possible impact of this.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We recommend that you never re-use any password or share your password with any third party to protect the security of your account. If you believe your account has been compromised, please notify HKC immediately. HKC cannot be held responsible for any losses resulting from your account being compromised.

Changes to this Legal Notice

This Legal Notice is effective as of date specified above and will remain in effect until further notice. We reserve the right to update or change our Legal Notice at any time and you should check this Legal Notice periodically. Your continued use of the Service after we post any modifications to the Legal Notice on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Legal Notice. If we make any material changes to this Legal Notice, we will notify you by placing a prominent notice on our website or in the app.

Jurisdiction

This Legal Notice applies to the use of HKC App’s to operate HKC smart products. In the event of any dispute all parties agree that the jurisdiction and laws of Republic of Ireland will be applied.

Contact Us

If you have any questions about this Privacy and Legal Notice, please use our Privacy Contact Centre.