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PROCELL® InSite BETA Privacy Notice

Effective Date: September 26, 2022

The Duracell U.S. Operations, Inc., a US company with offices located at 14 Research Drive, Berkshire Corporate Park, Bethel, CT 06801 (“we” or “us”) privacy notice in relation to your participation in the PROCELL® wireless battery consumption program through the PROCELL® InSite Beta testing application and website (hereinafter « PROCELL® InSite »). It describes the types of personal information that we receive from you when you decide to take part in the said
program, how we use that information, and/or third parties with whom we may share the information, and your choices in modifying or removing the information.

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 information. 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 information.

What information do we collect?

We provide you with the opportunity to register on our PROCELL® professional batteries device usage platform that could help you improve your company operational efficiency and battery usage reduce waste and improve your customers satisfaction.

In order to offer you this service and as part of your registration, 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.

• We will also receive information from your devices:
– ​Geolocation
– ​​Device Category used (e.g., Doorlocks, Dispensors)
– ​​Device Usage, e.g., estimated load, run time, cut-off voltage, RSSI values (“Received Signal Strength Indicator”)
– ​​Battery Type and number of batteries
– ​​​Device Name

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, it is your duty to provide a copy of this privacy notice to your employees whose personal data will be provide to, and used by Duracell, and inform them about their data privacy rights.

In PROCELL® InSite, you may further collect the following types of information:

• 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.

How do we use information we collect?

• Customer Personal Data. We use customer personal data only as necessary to deliver the services that a customer has agreed to use, which include, but are not limited to, the provision
of our notification services, customer support, and notification of new features and services. We may also use customer personal data to contact you regarding administrative notices, to resolve disputes, troubleshoot problems and enforce the customer services agreement. We will retain personal data (including geo-location data) provided by our customers for as long as is needed to provide the services to our customers and in accordance with the customer’s services agreement. In addition to this privacy notice, usage of customer personal data is subject to and covered by the applicable customer services agreement.

Information sharing

Third Parties with Whom We May Share Your Information

It may be necessary to share our customer 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. Transfers to these third parties are covered by the provisions in this privacy notice regarding notice and choice, as well as applicable contractual agreements.

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 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 customer data or a user’s personal data to others.

Information security

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 data transmitted to our site; any transmission is at your own risk. Once we have received your data, we will use procedures and security features designed to try to prevent unauthorized access.

Personal data retention period

We will retain personal data for the period necessary to fulfil the purposes outlined in any contracts or agreements, and this Privacy Notice unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

PROCELL® InSite User Activity Log for 90 days and then deleted.

Duracell will retains customer personal data stored in PROCELL® InSite application in a limited-function account for 90 days to enable customer to extract the data. After the 90-day retention period ends, Duracell disables the account and deletes the customer data.

Your California privacy rights

We don’t sell or share your personal data with anyone.. In accordance with California Civil Code Section § 1798.83, if you are a California resident, you have the right to request us to:

• Inform you of the personal data we collected about

• Be provided with access to the personal data that we collected

• Correct your personal data

• Delete your personal data

• Not to use your personal data for targeted advertising

• Not to use your personal data for automated decision making

• Not to use personal data for profiling

• Send your personal data to a third-party you designate

You should note that we do not use your personal data for targeted advertising, automated decision making, or profiling.


To submit a rights request, please send an e-mail to dataprivacy@duracell.com. We will not discriminate or retaliate against you for exercising your rights.

Your Virginia privacy rights

Effective January 1, 2023, the Virginia Consumer Data Protection Act (CDPA) goes into effect. We don’t sell or share your personal data with anyone. We also do not use your personal data for targeted advertising, or for automated decision making or profiling. In accordance with the CDPA Section § 59-1.573, if you are a California resident, you have the right to request us to:

• Inform you of the personal data we collected about

• Be provided with access to the personal data that we collected

• Correct your personal data

• Delete your personal data

• Send your personal data to a third-party you designate

• Not to use your personal data for targeted advertising

• Not to use your personal data for automated decision making

• Not to use personal data for profiling

• Appeal a decision we make to only partially or not be able to process any rights request that
submit

You should note that we do not use your personal data for targeted advertising, automated decision making, or profiling.
To submit a rights request, please send an e-mail to dataprivacy@duracell.com. We will not discriminate or retaliate against you for exercising your rights.

Privacy inquires

If you have any questions, inquiries, or complaints, please contact us at dataprivacy@duracell.com.

Changes to this privacy notice

We will post changes to this Privacy Notice and indicate the effective date when this Privacy Notice is updated. If we make any material changes to this Privacy Notice, we will notify you by posting notice of the changes on this website.