PROCELL® InSite Privacy Policy
Thank you for your participation in the PROCELL® InSite application and website (“PROCELL® InSite”). This Duracell U.S. Operations, Inc.,(“we” or “us”) privacy policy describes the personal information that we collect, use and disclose when you decide to take part in PROCELL® InSite program, the third parties with whom we may share your personal information, and your legal rights with respect to your personal information.
For purposes of this privacy policy, unless otherwise required by applicable law, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This may include, without limitation information which identifies you or which could be used to identify you such as your name and contact details, or your user account information. Personal information may also include information about how you use PROCELL® InSite. Personal information does not include information that is considered publicly available, aggregated, or deidentified under applicable law.
We value the trust you place in our products and services, and our privacy practices. We will adhere to the policies and practices described in this privacy policy, as well as any applicable customer agreement as it pertains to personal information.
What Information Do We Collect and From What Sources?
We collect personal information from and about you from various sources. This includes the following:
Directly from you:
When you register for an account through PROCELL® InSite, we ask you to provide your name, email address, phone number, and job title. We also collect information when you participate in any interactive features of PROCELL® InSite, fill out a form, make a purchase, apply for a job, express an interest in obtaining information about us or our products and services, communicate with us via third party social media sites, request customer support, or otherwise communicate with or contact us.
Information from PROCELL® InSite Devices:
We collect information when you activate or use PROCELL® InSite devices. We collect this information automatically in order to provide the PROCELL® InSite services through our website and applications.
Information from PROCELL® InSite applications and websites:
When you access or use the PROCELL® InSite website or applications, receive notifications from us about your PROCELL® InSite devices, we or our service providers use different technologies, including web server log files and cookies, web beacons, pixels, and other technologies, to automatically collect information. Cookies are small data files stored on your hard drive or in device memory that help us improve our services and your experience, see which areas and features of our services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our services and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see “Your Choices” below.
From third-party sources:
We may also obtain personal information about you from third-party sources, including from our service providers and other third parties as well as from publicly available sources. Additionally, we may collect contact information about you if your employer or your customer provides that information. Personal information collected by third parties is collected pursuant to their respective privacy policies, and we are not responsible for their privacy practices. We use personal information that we receive about you from third parties in accordance with this privacy policy.
PROCELL® InSite is further enabling you on top of tracking your company’s battery consumption to also send automated email and text message notifications to your maintenance teams in order for the same to perform any battery replacements if needed. For this, you would need to upload into PROCELL® InSite, the individual’s name and basic contact information (such as mobile number, work telephone, and e-mail address).
Consequently, if you provide personal information about someone else, such as your employees or contractors, it is your duty to get their permission and provide a copy of this privacy policy to your employees whose personal data will be provide to, and used by Duracell, and inform them about their data privacy rights.
Information We Derive:
We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.
Categories of Personal Information Collected:
We may collect the following categories of personal information, but only to the extent and in a manner consistent with applicable law:
- Personal identifiers and personal details. We collect personal identifiers (such as your name, email address, work address, job title, telephone number, and other contact details) and relevant personal characteristics. If you create an account, we ask you to provide your name, email address, and password.
- Device Information. When you activate or use PROCELL® InSite devices, we automatically collect information, including the device name, category of device used (e.g., door locks, dispensers, etc.), device usage information (e.g., estimated load, run time, cut-off voltage, signal strength indicators, etc.), number of batteries and battery type, and device geolocation information.
- Payment Information. We only collect your billing address and the form of payment (e.g., financial account, credit card, debit card, etc.) if you make a purchase or subscribe to the PROCELL® InSite services. Other billing information, such as your account number, credit card number, expiration date, card verification number, and billing address, may be collected on our behalf by our third-party payment processor, pursuant to its Terms of Service and Privacy Policy.
- Commercial and Preference Information. When you make a purchase, we may collect information about the transaction, such as product details, purchase price, and date and location of the transaction. We may also collect your order history, such as what products you have purchased.
- Internet and Network Activity Information. We may collect your IP address and the name of your internet service provider when you visit our website and applications. We also use tracking tools like cookies and pixels to passively collect information about how you interact with our website, applications, and online content. This might include device identifiers, the type of browser and operating system you are using, your browsing and search history on our website, what areas of our website and application you visit and for how long, what products or content you view and click on, what site you came from to get to us and what site you go to when you leave us, and your interactions with our digital ads and content on other sites. We may collect and record page interaction information and other electronic communications and content from your use of the Services, including content entry, mouse movements, screen captures, the search terms and other data you enter, and methods used to navigate away from the page. We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our partners/vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. We may engage or otherwise allow other parties to also collect information on our website and applications in these ways.
- Location information. We may collect information about your general location using your IP address and your zip code. As described above, we may also collect location information about your PROCELL® InSite devices.
- Audio information. We may monitor and collect activity and communications made when you interact with us or our service providers (such as through our phone and email systems). For example, we may record audio during customer service calls for quality assurance purposes.
- Inferences. We may draw inferences from any of the above categories in connection with the purposes stated as to such categories.
We collect these categories of personal information to carry out the purposes described in the “How Do We Use Your Personal Information” section below. All of the personal information we collect from or about you may be combined and used and disclosed as described in this privacy policy.
How Do We Use Your Personal Information?
We may use the personal information we collect in the following ways:
- Providing the PROCELL® InSite services. We use personal information as necessary to deliver the services , and provide notifications about PROCELL® InSite devices. and notifying you about new features and services.
- Product development, customer management, testing, improvement, and troubleshooting. We may use your personal information to answer your questions, provide customer support, troubleshoot problems, respond to your requests, send products and information, and develop new products and services. We may use your personal information to protect against or identify possible fraudulent transactions, secure, and protect the integrity of the PROCELL® InSite services. We may also use data collected automatically, including by cookies and other tracking technologies, to monitor and analyze how you use the website and application in order to provide statistics and improve the experience of interacting with our Services.
- Marketing. We may use personal information you voluntarily submitted to us to send you requested materials or provide personal information about our products, services, promotions, and competitions. If you have requested product information, or if you have bought products, we may also use your personal information and/or information that you provided to us or that is automatically collected when you interact with our website and applications to provide information about products or services we think may be of interest to you.
- As permitted to meet applicable legal obligations and establish and defend legal claims. We may, pursuant to valid legal process such as a search warrant, subpoena, or court order, use and allow access to any information provided to Duracell, in order to comply with such process and to protect our rights and property. We may also use customer personal data to contact you regarding administrative notices, to resolve disputes, and enforce agreements including our Terms and Conditions. If warranted, we may also use and allow access to this personal information where physical safety is at risk or when required by law and/or government authorities
- For other purposes disclosed to you when personal information is collected from you, or for other purposes for which we obtain your consent.
How Long Do We Retain Your Personal Information?
We will retain personal the personal information we collect for as long as necessary to provide the services to our customers and in accordance with the customer’s services agreement unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).. In addition to this privacy policy, usage of customer personal data is subject to and covered by the applicable customer services agreement.
With Whom Do We Disclose Your Personal Information?
We do not “sell” or “share” your personal information with third parties outside of Duracell. We disclosure your personal information with third parties as described below:
Third-party service providers:
We rely on third-party service providers to perform a variety of business operations on our behalf. Accordingly, it may be necessary to disclose personal information with these third-party service providers in order for us to provide the services. These services are carried out for the business purposes described in the How Do We Use Your Personal Information?” section of this privacy policy. 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 policy, including:
- To store data via third-party hosting services;
- To enable you to receive notifications;
- On a need-to-know basis to assist us in operating PROCELL® InSite 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.
We do not sell, trade, or rent personal information with third parties.
Information Security
We are committed to keeping personal information secure. We have implemented technical, administrative, and physical measures designed to protect personal information from loss, misuse, or alteration.
The transmission of information via the internet is not completely secure. Although we have taken measures to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
Children’s Online Privacy
PROCELL® InSite services are not directed to individuals under the age of 16. If you are under the age of 16, do not use our services or provide us with any personal information. We do not knowingly collect personal information online from children under the age of 16 or as defined by local legal requirements. If you are a parent or guardian of a child under the age of 16 and believe that child has provided their personal information on our services without your consent, please contact us at dataprivacy@duracell.com and we will delete that personal information in accordance with applicable law.
Your Privacy Rights
Certain jurisdictions have specific legal requirements and grant privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. You may be able to use our services to access and update the personal information that you have provided to us. You may also exercise these rights by submitting a request as described in the “How to Submit a Request” section below.
If you are a resident of the United States, please read the “Information for Individuals Located in the United States” section of this Privacy Policy. If you are resident of California, please also read the “Additional Notice for California Residents” section of this Privacy Policy. You may have additional rights in relation to your personal information.
If you are resident of Virginia or Colorado, please also read the “Additional Notice for Colorado, Connecticut, and Virginia Residents” section of this Privacy Policy. You may have additional rights in relation to your personal information.
If you are resident of Nevada, please also read the “Additional Notice for Nevada Residents” section of this Privacy Policy. You may have additional rights in relation to your personal information.
Information for Individuals Residing in the United States
If you are a resident of the United States, your state of residence may provide you additional rights in relation to the processing of your personal information. Further to the information set out in the “Your Privacy Rights” section of this Privacy Policy, the following additional information may apply to you. Unless otherwise required by applicable law, the following terms shall have the following meanings:
- “process” or “processing” means any operation or set of operations performed, whether by manual or automated means, on personal information or on sets of personal information, such as the collection, use, storage, disclosure, analysis, deletion or modification of personal information.
- “targeted advertising” or “cross-context behavioral advertising” means displaying advertisements to a consumer where the advertisement is selected based on personal information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests.
- “sale” or “sell” means renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.
- “share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, personal information to a third party for cross-context behavioral advertising.
- “profiling” means any form of automated processing of personal information to evaluate certain personal aspects relating to a natural person and in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at dataprivacy@duracell.com. You may exercise the rights given to you by your state of residence by submitting a request as described in the “How to Submit a Request” section below.
Right to Know and to Access: Subject to certain exceptions, and legal obligations, you may have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information, such as the following:
- The categories of personal information we collected about you;
- The categories of sources of that information;
- The business or commercial purposes for which we collect, sell or share personal information about you;
- The categories of personal information about you that we have disclosed about you and the categories of persons or vendors to whom it was disclosed for a business purpose; and
- The specific pieces of personal information we have collected about you.
This information is disclosed above in the “What Personal Information Do We Collect and From What Sources?” section. To protect your personal information, we may request additional information to verify your identify before we act on your request. To the extent legally required, we will provide the information you request, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We may provide this information to you via email to the email address you have provided with your request.
Right to Correction: You may have the right to request that we correct any inaccurate personal information we maintain about you. In response to your request, we may request additional information showing that the information you want to correct is inaccurate.
Right to Deletion: You may have the right to request that we delete your personal information. This right is subject to certain exceptions, and legal obligations imposed by state or federal laws including, without limitation, privacy and employment laws. We will delete or deidentify personal information not subject to one of these exceptions from our records and, to the extent required, we will direct our service providers to take similar action.
Right to Opt-Out: Depending on where you reside, you may have the right to opt-out of the processing of your personal information for the purpose of (i) the sale or sharing of your personal information by Duracell to third parties, (ii) targeted advertising, or (iii) profiling.
Non-Discrimination or Retaliation: We will not discriminate or retaliate against you for exercising any of your data privacy rights.
Additional Notice for California Residents
Right to Limit Use and Disclosure of Sensitive Personal Information: Under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), you have the right to direct us to limit our use of your sensitive personal information that we use to infer characteristics about you to that use which is necessary to fulfill the purposes reasonably expected by an average consumer who requests those goods or services. California law considers the following pieces of personal information to be “sensitive:” social security number, driver’s license number or other government-issued identification number (e.g. passport numbers), financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data. We do not use sensitive personal information, but if we do, it is only used as it is necessary to fulfill the purposes for which it was collected and not to infer characteristics about you.
Categories of Personal Information Sold or Shared to Third Parties:
Duracell does not sell and has not sold your personal information or transferred personal information to third parties to use for their own benefit in the preceding 12 months. Duracell also does not share your personal information for targeted or cross-context behavioral advertising, except as described below. Relatedly, we do not sell or share personal information of California residents under 16 years of age.
“Share” and “sharing” as used in this section, does not include transfers of personal information described in this Privacy Policy as part of a corporate business transaction, such as a merger, acquisition, or joint venture, or in the event of insolvency, bankruptcy, or receivership. Should such an event occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Policy.
Categories of Personal Information Disclosed to Service Providers:
We disclose personal information to certain third parties to enable them to fulfill the purposes described in the “How Do We Use Your Personal Information” section of the Privacy Policy above. The personal information provided to our service providers is limited to that personal information which is necessary for them to fulfill these purposes. Our service providers have contractually agreed not to use your personal information other than as necessary to fulfill the applicable purposes and in accordance with the CCPA. In the preceding 12 months, we have disclosed the categories of personal information described above in the “What Personal Information Do We Collect and How?” section, with the following categories of service providers:
- Marketing and Advertising Providers
- Operating Systems and Platforms
- Customer Support Providers
- Payment Processing Providers
- Distribution and Resale Providers
We disclose personal information to our service providers in accordance with the purposes described in the “How Do We Use Your Personal Information” section of the Privacy Policy above.
Sensitive Personal Information:
To the extent any of the personal information we collect is sensitive personal information, we collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CCPA. We do not sell or share sensitive personal information.
California “Shine the Light” Law:
Under California’s “Shine the Light” law, California residents may also request that we provide to you:
- a list of the categories of personal information about you that Duracell has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request; and
- a list of the categories of third parties to whom we disclosed such personal information.
To submit your request, please email dataprivacy@duracell.com and reference “Shine the Light” in the subject line.
Additional Notice for Colorado, Connecticut, and Virginia Residents
Right to Appeal:
If you are a Colorado, Connecticut, or Virginia resident that made a request to exercise any of the above data access rights, and we are unable to comply with your request, you may request to appeal our decision within a reasonable period time by contacting us at dataprivacy@duracell.com with the subject line “Data Access Request Appeal.” Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If after you complete the appeal process with us, you are still not satisfied with our response, you may contact your Attorney General to file a complaint. Below are the contact information for the appropriate entity where you can inquire about filing an appeal:
- For Colorado residents, to the Colorado AG at https://coag.gov/file-complaint/
- For Connecticut residents, to the Connecticut AG at https://www.dir.ct.gov/ag/complaint/
- For Virginia residents, to the AG at https://www.oag.state.va.us/consumercomplaintform.
How to Submit a Request
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to you. For example, consumers may be required to submit their email address, and may also be asked to provide their name, location, and telephone number so that we can verify the request.
Certain states allow their residents to use an authorized agent to make privacy rights requests. We require an authorized agent to provide us with proof of the data subject’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the data subject.
The verification steps we take may differ depending on your jurisdiction and the request. If possible, we will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it in accordance with applicable law. If we cannot verify your request, we may ask you for additional information to help us verify your request.
We will respond to your request within the time period required by applicable law. When we are not able to fully address your request, we will notify you.
Please direct requests (with a return email address where possible):
- By webform: Privacy Request
- By email: dataprivacy@duracell.com
- By phone: 800-551-2355
Changes to This Privacy Notice
We will post changes to this privacy policy and indicate the effective date when this privacy policy is updated. If we make any material changes to this privacy policy, we will notify you by posting notice of the changes on this website.
Contact Duracell
If you have any questions, inquiries, or complaints about the collection or use of your personal information, please contact us at: dataprivacy@duracell.com or call us at 800-551-2355. You may also write to us at the following address: 14 Research Drive, Berkshire Corporate Park, Bethel, CT 06801.