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PROCELL® InSite Privacy Notice

Effective Date: November 1st, 2024

1. Introduction

This privacy notice applies to the processing of personal data in relation to your participation in the PROCELL® wireless battery consumption program through the PROCELL® InSite platform (hereinafter “PROCELL® InSite platform”) which is made available by Duracell International Operations Sàrl, a Swiss company with its registered address at Rue du Pré-de-la-Bichette 1, 1202 Geneva (“Duracell”, “we” or “us”) and its affiliates. It describes the types of personal data that we receive from you when you use the platform, how we use that information, and/or (if any) the third parties with whom we may share the information, and your choices in modifying or removing the personal data.

The use of the PROCELL® InSite platform is subject to the Procell InSite Software Licensing Agreement.

The processing of personal data via the PROCELL® InSite website, available at https://www.procell.com is subject to a separate privacy notice . Please read these documents together with this privacy notice. 

We value the trust you place in our products and services, and our privacy practices. We are committed to providing our customers and users with a secure environment, and state of the art technologies to safeguard your personal data. We will adhere to the policies and practices described in this privacy notice, as well as any applicable customer agreement as it pertains to personal data.

2. Who is responsible for the processing of your personal data?

  • Duracell as controller for client management and invoicing, monitoring, analysis and development of the PROCELL® InSite platform

Duracell only processes personal data on its own initiative, without receiving any instruction from another party, in limited cases, i.e. for client management and invoicing in relation to, creation of aggregated and anonymized data and development of, the PROCELL® InSite platform. In these cases, Duracell will act as a controller of your personal data.

  • Customer as controller for the processing of personal data in the provision of the PROCELL® InSite platform

In the provision of the PROCELL® InSite platform to its customers, Duracell acts as a processor and processes personal data on behalf of its customers for the creation and provision of the personal accounts of the customer’s employee or contractors to use the PROCELL® InSite platform. The processing by the customer is subject to the customer’s privacy notice.

3. What personal data do we collect?

We provide you with the opportunity to register on our PROCELL® InSite platform that could help you improve your company’s operational efficiency and battery usage, reduce waste and improve your customer satisfaction.

As part of your registration to the PROCELL® InSite platform, we will have access to, and you will need to provide to us: 

  • Your identification data: name, surname, job title, business phone number and email.
    Your company name, and registered address.

In PROCELL® InSite, you may further collect the following types of Personal Data for the monitoring, analysis and development of the PROCELL® InSite platform: 

  • Usage details and number of logins. Certain details of your access to and use of PROCELL® InSite, including traffic data, logs and other communication data, and the resources that you access and use on PROCELL® InSite application. We use analytics software to allow us to better understand the functionality of our PROCELL® InSite application. This software may record information such as: how often you use the application, the events that occur within the application, aggregated usage, performance data. We do not link the information we store within the analytics software to any personal data you submit within our PROCELL® InSite application.
  • Device information. We may collect information about your device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, network information and the device’s telephone number.

We use this information to monitor, analyze and improve our PROCELL® InSite application.

We use cookies or similar technologies for conducting the monitoring, analysis and development of the PROCELL® InSite platform. You can find further details in the cookie notice applicable to the PROCELL® InSite application. The cookie notice is available at https://www.procell.com/en-gb/insite/

4. How do we use your personal data and on what legal basis?

To manage invoicing and customer management processes
We use personal data to create, send and follow-up on invoices that may incorporate your personal data; as well as for general customer management purposes (i.e. addressing questions or concerns with regard to the service).

The processing for this purpose is necessary for the legitimate interest of Duracell to invoice its services, to manage its customers and to ensure the proper performance of the agreement between Duracell and its customers.

To improve the technicalities of the PROCELL® InSite platform (Monitoring, analysis and development of the PROCELL® InSite platform)
We use personal data to better understand the functionality of our PROCELL® InSite platform via analytics software.

Where legally required, we will request your prior consent (e.g. the processing through non-essential cookies and tracking technologies).
In other cases, we rely on our legitimate interest to improve our applications and services.

To aggregate and anonymise personal data

In order to improve our business operations, create statistics and support the development of the PROCELL® InSite platform and other research & development activities, we aggregate and anonymise personal data that can be found within the PROCELL® InSite platform.

The processing for this purpose is necessary for the legitimate interest of Duracell to create aggregated and anonymized data for various business operations such as creation of statistics, development of the PROCELL® InSite platform and other research & development activities.

5. With whom do we share your personal data?

It may be necessary to share your personal data with third parties in order for us to provide the services requested by our customers. For example, we will need to transmit an individual’s cell-phone number to a telecommunications provider in order to deliver a customer-initiated notification designated for that individual and others. Under such circumstances we will only transmit the information needed to fulfil the obligations described in our customer’s service contract. These third parties are also bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

We may disclose personal information about you as described in this privacy notice, including: 

  • To store the data via third-party hosting services;
  • To the extent required to enable you to receive notifications;
  • To our third-party service providers on a need-to-know basis to assist us such as operating the PROCELL® InSite platform or providing services to you;
  • To our subsidiaries and affiliates to provide support to you in connection with our websites or Duracell services;
  • As required by law, such as to comply with any court order, subpoena, or similar legal process, including responding to any government or regulatory request, as well as lawfully binding requests by public authorities to meet law enforcement requirements.

Information Transfer Your personal data may be transferred and stored in countries outside your place of residence, that are subject to different standards of data protection. This may include the United States. When we do so, we transfer your personal data in compliance with applicable data protection laws. We have implemented procedures and controls to help ensure that personal data is protected no matter what country it is stored in or transferred to. You have a right to contact us for more information about the safeguards we have put in place, including a copy of relevant contractual safeguards, to ensure the adequate protection of your personal data when this is transferred as mentioned above.

6. Security of personal data

We are committed to keeping personal data secure. We have implemented technical, administrative, and physical procedures designed to protect personal data from loss, misuse or alteration. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will have taken measures to protect your personal data, we cannot guarantee the security of your personal data transmitted to the PROCELL® InSite platform; any transmission is at your own risk. Once we have received your personal data, we will use procedures and security features designed to try to prevent unauthorized access. 

7. How long do we keep your personal data

We will retain personal data for the period necessary to fulfil the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements) thereby taking into account any statutory retention or limitation periods. 

Usage details, number of logins and device information (see section 3) are deleted 90 days after an account becomes unused and then deleted.

8. What rights do you have

Under the conditions provided for by applicable law, you have the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
  • Request correction of any incomplete or inaccurate personal data that we hold about you.
  • Request erasure of your personal data when there is no need for us continuing to process it or you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal data to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it.
  • Withdraw your consent at any time. Such withdrawal shall however not affect the lawfulness of the processing based on consent before its withdrawal. See the cookie notice applicable to the PROCELL® InSite application for more details.
  • Request the transfer of your personal data to another party (“data portability”).

To exercise any of the above rights, you can send an email to dataprivacy@duracell.com. This email must be accompanied by a means of verification of your identity (e.g. a copy of the front of your identity card or driving licence). Duracell may, however, refuse requests which it considers excessive or to be an abuse of the relevant law.

You also have the right to lodge a complaint with the competent supervisory authority of your place of habitual residence or work or where an alleged infringement took place. The list of the data protection authorities in the European Economic Area is available here.

9. How to contact us?

If you have any questions or concerns regarding your privacy while using the PROCELL® InSite platform, please contact us at dataprivacy@duracell.com.

10. Changes to this privacy notice 

If Duracell changes its privacy practices, an updated version of this privacy notice will reflect those changes and we will notify you of such changes by updating the effective date at the top of this privacy notice. Without prejudice to your rights under applicable law, Duracell reserves the right to amend this privacy notice from time to time to reflect technological advancements, legal and regulatory changes and good business practices.