LenelS2 Privacy Notice

Elements Access Control as a Service

Carrier Fire & Security Americas Corporation (“LENELS2”) is committed to protecting the privacy of users of its Elements Access-Control-as-a-Service (“Elements”) applications, including the Elements Customer and Reseller web Portals (“Portals”), (collectively “Apps”) and related services (“Services”). It is important that our users understand how we collect, use and disclose Personal Information (as defined below).

This Privacy Notice describes our practices related to Personal Information collected through LENELS2’s Elements Apps and Services.

LENELS2 will not collect, use, share or disclose your personal information through its Apps or the Services other than as set forth in this notice.

Summary:

We use Personal Information to provide the Apps and Services.

Through the Apps and Services, resellers, end users or end user administrators provide Personal Information to LENELS2 in accordance with the terms and conditions related to the Apps and Services and this Privacy Notice. If you have questions or concerns about the Personal Information that a reseller, end user or end user administrator provides to LENELS2, please contact that reseller or end user for more information.

We don’t sell your Personal Information.

We don’t use your Personal Information to contact you for marketing or advertising or share your Personal Information to third parties for their direct marketing.

You can reach us at LenelS2.Privacy@carrier.com with any concerns or questions about this notice or your data privacy.

Read on for more information.

What Personal Information does LENELS2 collect? How does it collect such Information?

“Personal Information” is information through which a natural person is identifiable or may be identified.

LENELS2 collects, uses and processes your Personal Information in order to provide the Apps, Services, products or information that you request or as otherwise detailed in this Privacy Notice. This includes name, email address, password and other information that you choose to submit through the Apps. If you choose not to provide any of the Personal Information requested, LENELS2 may be unable to complete your transaction, or provide the information, services or products you have requested.

LENELS2 collects information through your use of our Apps, such as log files and usability metrics.

A reseller, end user or end user administrator may submit Personal Information on behalf of others in order to use the Apps and Services. This Personal Information, which may include name, email address, photo, and badge number, is processed by LENELS2 at the direction of the reseller or end user, in order to use the Apps and Services. It is the obligation of the reseller or end user to provide notice to those individuals for whom Personal Information is provided to LENELS2 for use of the Apps and Services. LENELS2 does not use such Personal Information other than to provide the Apps and Services to you, the reseller and end user or as set forth in this Privacy Notice. If you have questions or concerns about the Personal Information that a reseller, end user or end user administrator provides to LENELS2, please contact that reseller or end user for more information.

We might need to collect other information for a specific form, feature, or other service that you may use or request. The content of such information will vary depending on the method of collection and the specific purpose(s) for which the information is being collected, but the request for information will be transparent to you and be specified as needed.

Why does LENELS2 collect your Personal Information?

Our purpose in collecting this information is to provide services to you. Your information may be used by LENELS2 to carry out our contractual obligations, authenticate you as a user and allow you to use certain functions of our Apps.

Personal Information collected on the App will be used to:

• Provide requested information, items, or services;
• Protect against fraud or investigate suspected or actual illegal activity;
• Screen against sanctions and antiterrorism lists as required by law;
• Respond to a legitimate legal request from law enforcement authorities or other government regulators;
• Develop new offerings, improve the quality of our products, improve and personalize user experience, and better prepare future content based upon your interests and those of our general user population; or
• Conduct investigations to ensure compliance with, and comply with, legal obligations.

Except where used in support of our Terms and Conditions with you, a reseller, end user or end user administrator or to fulfill a legal obligation, our use of your Personal Information will be only for legitimate business interests as set out above.

We will not use Personal Information for materially different, unrelated or incompatible purposes without providing you with notice and/or updating this Privacy Notice.

Where is Personal Information stored?

LENELS2 stores your Personal Information in the United States. However, because LENELS2, and its parent company, Carrier, are global companies with locations in many different countries, we may transfer your information from one legal entity to another or from one country to another within the LENELS2 and Carrier group of companies in order to accomplish the purposes listed above. These countries include, at a minimum, the member states of the European Union, Switzerland, the United Kingdom, Canada, India and other countries. We will transfer your Personal Information consistent with applicable legal requirements and only to the extent necessary for the purposes set out above. Within the Carrier and LENELS2 group of companies, information is transferred subject to the Binding Corporate Rules.

LENELS2 relies on available legal mechanisms to enable the legal transfer of Personal Information across borders. To the extent that Carrier relies on the standard contractual clauses (also called the model clauses) or Binding Corporate Rules to authorize transfer, LENELS2 will comply with those requirements, including where there may be a conflict between those requirements and this Privacy Notice.

Does LENELS2 use your Personal Information to contact you?

If you choose to provide Personal Information to LENELS2 through other channels, LENELS2 may use the Personal Information you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you prefer not to receive such communications, please use the “unsubscribe” function within the email, or let us know by sending an email to LenelS2.Privacy@carrier.com. Also, LENELS2 will ensure that any marketing communications sent by electronic means will provide a simple method for you to opt-out or unsubscribe. Please note that if you unsubscribe from marketing communications, you may continue to receive communications about our account or transactions with us.

Does LENELS2 share the information it collects?

LENELS2 may share your Personal Information with our affiliated companies, such as companies in Carrier’s group of companies, and/or companies in which LENELS2 has control, through either direct or indirect ownership solely for the purposes set out above.

LENELS2 will not sell or otherwise transfer or share your Personal Information outside of the companies identified above, except to:

• Service providers, agents or contractors that LENELS2 has retained to perform services on our behalf. LENELS2 will only share your Personal Information with third parties whom LENELS2 has contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements;
• Comply with legal obligations, such as in response to a legitimate legal request from law enforcement authorities, courts or other government regulators or authorities, among other things;
• Investigate suspected or actual illegal activity;
• Prevent physical harm or financial loss; or
• Support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

Your Personal Information may also be maintained and processed by our service providers in the United States, the member states of the European Union, Switzerland, the United Kingdom, Canada, Asia, and in other jurisdictions.

How does LENELS2 secure Personal Information?

LENELS2 is committed to maintaining the security, availability and integrity of Personal Information. LENELS2 has adopted reasonable physical, electronic and managerial procedures to safeguard your Personal Information. However, due to the nature of Internet communications, we cannot guarantee or warrant that your transmissions are secure, so transmission of information is entirely at your own risk. LENELS2 shall periodically re-evaluate the measures adopted to ensure that they remain reasonable and appropriate at all time, subject to the evolution of relevant best-practices.

How can you access, correct, change or delete your information held by LENELS2?

Please contact your reseller, end user or end user administrator for information on how you can access, update, correct, change or delete the Personal Information in the App or Services. LENELS2 will use reasonable efforts to timely update and/or remove information upon request, however it is a processor, not a controller, of that Personal Information. Deletion of Personal Information will likely impact the ability to use or access the Apps and Services. To protect the user’s privacy and security, LENELS2 will take steps to verify the user’s identity before making any requested change. To access, change, or delete your Personal Information or to ask questions or to raise concerns, send an email to LenelS2.Privacy@carrier.com.

Please note that while we will assist you in protecting your Personal Information, it is your responsibility to protect your App, passwords and other access credentials from others.

What should you understand about the third party links that may appear in this App or as part of these Services?

In some instances, LENELS2 may provide links to non-LENELS2 controlled websites, which LENELS2 will make reasonable efforts to identify as such. LENELS2 does not control such third party websites, however, and cannot be responsible for the content or the privacy practices employed by other websites. Furthermore, this Privacy Notice does not govern information collected about you by third parties. We do not accept any responsibility or liability for those practices whatsoever as we have no control over them.

How does LENELS2 use cookies or other tracking technologies?

Our Apps make use of cookies and other local storage to track your session. This includes your name and your permissions in our Apps and Services. Our Apps may also use this tracking technology for quality, performance and usability analysis. However, no Personal Information will be transmitted to third-parties via cookies or tracking technologies.

How long do we keep your Personal Information?

Any Personal Information you provide to LENELS2 is only kept for as long as it is reasonably necessary for the purposes for which it was collected, taking into account our need to comply with contractual obligations, resolve customer service issues, comply with legal requirements and provide new or improved services to users. This means that we may retain your Personal Information for a reasonable period after you stopped using the App. After this period, your Personal Information will be deleted from all systems of LENELS2 without notice.

Aggregated and Non-Personal Information

This Privacy Notice does not apply to non-personal information. LENELS2 may use aggregated and non-personal information to analyze our Apps and Services, including how users use them, and for our general business purposes, including developing new products and services.

What additional information should specific users know?

Parents, Guardians, and Children: Our Apps are intended for users who are at least 18 years of age, or the age of majority in their jurisdiction of residence. LENELS2 does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your Personal Information on this or any other LENELS2 website or App.

Users from California: LENELS2 does not disclose or share your Personal Information with other businesses for their direct marketing purposes. Annually California residents may request and obtain information that LENELS2 shared with other businesses for their own direct marketing use within the prior calendar year (as defined by California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which LENELS2 shared this information in the immediately preceding calendar year. To obtain this information, please send an email message to LenelS2.Privacy@carrier.com with “California Shine the Light Privacy Request” in the subject line as well as in the body of your message.

If you are a resident of California, effective January 1, 2020, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”), including the right to:

(a) know what categories of personal information about you we have collected and used, including how the personal information was collected and the purpose for the collection and use;

(b) know what categories of personal information are being sold or disclosed to third parties and, if sold or disclosed, the categories of third parties receiving it;

(c) access specific personal information collected about you;

(d) request that your personal information be deleted.

Requests to exercise rights under the CCPA are subject to verification by LENELS2 and are also subject to certain restrictions provided by the CCPA. We will not discriminate against California residents for exercising any of their applicable CCPA rights.

While California residents have the right to opt-out of the sale of their personal information under CCPA, LENELS2 does not sell personal information to any third parties. If our practices change, we will update this Privacy Notice and take any other necessary action to comply with applicable law.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at LenelS2.Privacy@carrier.com or 833-617-0050. When contacting us to exercise your rights, please put “California Privacy Rights” in the subject and body of your request and describe the nature of your request.

Users from the EU: You have the right to lodge a complaint with your national or state data protection authority, which may also be known as a supervisory authority. You also have the right to: (i) request access to and correction or erasure of your Personal Information; (ii) seek restrictions on; or (iii) object to the processing of certain Personal Information, and seek data portability under certain circumstances. To contact LENELS2 about a request to access, correct, erase, object or seek restrictions or portability, please use the contact methods indicated at the end of this notice.

How might LENELS2 change this Privacy Notice?

As LENELS2 expands and improves its Services and its Apps, we may need to update this Privacy Notice. This Privacy Notice may be modified from time to time without prior notice. We encourage you to review this Privacy Notice on a regular basis for any changes. However, if we materially change our Privacy Notice, we will identify those changes at the top of this Privacy Notice.

How can you contact LENELS2?

If you have any comments or questions about this Privacy Notice or to obtain information on the manner in which we or our service providers treat your personal information, or if you have questions about LENELS2’s privacy practices in general, please email LenelS2.Privacy@carrier.com.

In the event that you are located in a country that will be governed by the General Data Protection Regulation and would like to contact the local Data Protection Officer, please note that in your email and your inquiry will be directed to the appropriate person. If you wish to opt-out from sharing your Personal Information with us or have your Personal Information deleted, you should email LenelS2.Privacy@carrier.com.

Last updated on  September 22, 2021.

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