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LenelS2 Privacy Notice
BlueDiamond Mobile Apps & Services

Carrier Fire & Security Americas Corporation (“LENELS2”) is committed to protecting the privacy of users of its BlueDiamond™ mobile applications (“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 BlueDiamond Apps and Services.

This version of the LenelS2 Privacy Notice makes updates to reflect the option for a user of the Apps to elect to save certain of their Apps settings and preferences in the BlueDiamond Cloud.

The Bottom Line:

We use your Personal Information to provide you with the Apps and Services.

Location services can be used for the Apps’ Pathways feature and other positioning features, but you don’t have to.  When you use location services, that location information is collected by your device and shared with a third-party service provider, but LENELS2 does not have access to it unless you elect to back up your Apps settings and preferences to the BlueDiamond cloud.

You may elect to back up your Apps settings and preferences to the BlueDiamond cloud, including your Pathways and other positioning features’ settings and preferences, but you don’t have to.  When you elect to back up your settings and preferences to the BlueDiamond cloud, LENELS2 does have access to those settings and preferences, but only for the purpose of hosting and making those settings and preferences available to you for use on a new or reset device and to provide technical support.

You can reach LENELS2  via email at [email protected], or by mail at 1212 Pittsford-Victor Road Pittsford, New York, 14534, U.S.A., with any concerns or questions about this Privacy 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 any information that relates directly or indirectly to a natural person.

LENELS2 collects, uses, and processes your Personal Information in order to provide you with the Apps and Services and other services, products, or information that you request.

The collection of information, including Your Personal Information, will be transparent to you, and you will have the opportunity to decide whether or not to provide it. 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, including but not limited to the Apps and Services. For example, you will not be able to use the Apps’ Contact Notification feature if you choose not to provide COVID-19 self-assessment responses.

LENELS2 collects information through your use of our Apps and Services, such as device identifiers and log files. LenelS2 does not use cookies, web beacons or other tracking technologies in the Apps or Services.  

If you are using the Apps’ Pathways feature or other positioning features, the Apps collect your physical location when the Apps are in use (such as via GPS); however,  that physical location information is not transferred to LENELS2, but will be collected by LENELS2’s service providers.  Note that any location settings and preferences you choose to create a particular, reusable Pathway will be backed up, if you elect to back up your Apps settings and preferences to the BlueDiamond cloud).  (See “How may LENELS2 use and share location data?” below for more information on the Apps’ Pathways feature and positioning features and location data). 

We might also 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.

Except to the extent specifically requested from you by the Apps or Services, such as by the Apps’ Contact Notification feature, the Apps and Services are not intended to collect or process Sensitive Personal Information. As such,  do not enter or store in the Apps any Sensitive Personal Information not specifically requested of you by the Apps or Services, including but not limited to any data revealing racial or ethnic origin, political affiliations or opinions, rreligious or philosophical beliefs, union memberships, or genetic, biometric or health data.

Why does LENELS2 collect your Personal Information?

Our purpose in collecting this information is to provide the Apps, Services and other information, services or products you have requested. If collected, your Personal Information will be used by LENELS2 to carry out our contractual obligations, including but not limited to authenticating you as a user and allowing you to use certain functions of the Apps and Services.

Personal Information collected on the Apps and Services will also be used to:

 

-        execute our contractual obligations, as laid out in the BlueDiamond Mobile Apps and Services End User License Agreement.

·       Provide requested information, products, items, or services, including the Apps and Services;

·       Obtain your location data in order to provide requested information or services (but LENELS2 will not have access to that location data, only the service provider for location services will, however, any location settings and preferences you choose to create a particular, reusable Pathway will be backed up, if you elect to back up your Apps settings and preferences to the BlueDiamond cloud);

-        comply with legal obligations:

·       Screen against sanctions and antiterrorism lists as required by law;

·       Respond to a legitimate legal request from law enforcement or judicial authorities or other government regulators;

-        satisfy LENELS2’s legitimate interests:

·       Protect against fraud or investigate suspected or actual illegal activity;

·       Develop new offerings, improve the quality of our products, services and processes, including the Apps and Services, 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.

Where is Personal Information stored?

LENELS2 stores your information in the United States.  However, because LENELS2, and its parent company, Carrier Global Corporation (“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, and other countries, including some in Asia and Central and South America. We will transfer your Personal Information consistent with applicable legal requirements and only to the extent necessary for the purposes set out above.

CARRIER and LENELS2 rely on adequate contractual provisions, as well as technical and organizational security measures, to enable the transfer of Personal Information across borders.

Does LENELS2 use your Personal Information to contact you?

LENELS2 does not use the information collected through the Apps and Services to contact you. 

If you choose to provide Personal Information to LENELS2 through channels other than the Apps and Services, 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 [email protected]. 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 your account or transactions with us.

Does LENELS2 share the information it collects?

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

If you use the Apps’ Pathways feature or other positioning features, the Apps will utilize location services, such as Google Maps® or Google Places®, in order to provide you with that service.  This requires the Apps to share your Personal Information, including location information, with the service provider for location services.  In addition, if you elect to back up your Apps settings and preferences to the BlueDiamond cloud, your Personal Information related to your Pathways and positioning feature settings and preferences will be stored on the BlueDiamond cloud and accessible by LENELS2 in order to make those settings and preferences available to you for use on a new or reset device. (For more information on the Apps’ Pathways feature, see “What is Pathways and how do the Apps use location data?” below).

The Apps use Bluetooth permissions to detect and communicate with nearby BlueDiamond readers. When the Apps’ Contact Notification feature is used and its optional social distancing feature enabled, the Apps will use Bluetooth technology to detect and communicate with other nearby mobile devices to alert the users to observe distancing policy parameters.


The Apps use “read or write to external file storage” permissions to download and save the BlueDiamond credential certificate which contains device-specific “signatures” required to communicate with the BlueDiamond readers for door access. 

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

  • Service providers, dealers, distributors, resellers, agents, or contractors that LENELS2 has retained to perform services on our behalf or authorized to sell our products and services. 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, sell our products and services or to comply with legal requirements;

·       To a facility subscribing to the instance of the Apps you are using, where such facility requests details of the SSID/BSSID data of Apps users at their facility for their own analytic purposes, which may include gaining a better understanding of how many, or which, of their Apps users are connected to which Wi-Fi networks within their facility. Such SSID/BSSID data will not be shared in a manner that connects it with an Apps user’s identity;

  • 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 damage 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 will 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, Central and South America and in other jurisdictions.

What is Pathways and how do the Apps use location data?

If you choose to use the Apps’ Pathways feature, you will have the opportunity to enable location services to create your own “Pathway”.  You can also choose not to use the Apps’ Pathways feature or other positioning features and location services, but you will need to manually create and manually initiate your chosen Pathway in the Apps to use that functionality.  Choosing not to use the Apps’ Pathways feature or other positioning features entirely will not decrease your ability to use other functions of the Apps or Services.

If you are using the Apps’ Pathways feature or other positioning features with location services, the Apps will collect location data generated by your use of the Apps’ software and the Services on your mobile device.  The location data includes your set GPS location when you reach your selected location,and this GPS location information is kept on your mobile device and used by the location services provider, in the case of the Apps and Services, Google® (for Google Maps® and/or Google Places®, please review the privacy terms for those products if you have questions). In order to use the Apps’ Pathway feature, the Apps also requires access to your Wi-Fi status permission to determine your exact location.  LENELS2 uses this location data to provide you the ability to use the Apps’ Pathways feature or other positioning features. LENELS2 will ask permission to collect your location data and so the collection of this location data will be transparent to you – you will have the opportunity to decide whether or not to provide your location data.

The Apps collect location data to enable the Pathways frequently travelled route feature and other positioning features with location services to function even when the Apps are closed or not in use. 

If you elect to back up your Apps settings and preferences to the BlueDiamond cloud, your Personal Information related to your Pathways and positioning feature settings and preferences, including but not limited to your preferred or frequently travelled routes, will be stored on the BlueDiamond cloud and accessible by LENELS2 for the purpose of making those settings and preferences available to you for use on a new or reset device..

How does LENELS2 secure Personal Information?

LENELS2 is committed to ensuring 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 transmission to us is secure. LENELS2 shall periodically re-evaluate the measures adopted to ensure that they remain reasonable and appropriate at all time, subject to the evolution of the industrial best-practices.

How can you correct, change, or delete your Personal Information held by LENELS2?

You may request to access, update, correct, change, or delete your Personal Information from the LENELS2 system at any time. LENELS2 will use reasonable efforts to timely update and/or remove information; however, this will likely impact your ability to use or access LENELS2’s services, including the Apps and Services.  To protect the user’s privacy and security, LENELS2 will take steps to verify the user’s identity before providing any requested access or making any requested change. To access, updated, correct, change, or delete your Personal Information or to ask questions or to raise concerns, send an email to [email protected].

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

What should you understand about the third-party links that may appear in the Apps 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.

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 Apps and Services. After this period, your Personal Information will be deleted from all systems of LENELS2 without notice.

What additional information should specific users know?

Parents, Guardians, and Children: The Apps and Services 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 Apps.

Users from California:

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:

  1. 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;
  2. 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;
  3. access specific personal information collected about you;
  4. request that your personal information be deleted.

Requests to exercise rights under the CCPA are subject to verification by Carrier 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, Carrier does not sell personal information to third parties. If our practices change, we will update this Privacy Notice and take any necessary action to comply with applicable law.

California residents who wish to exercise their CCPA rights can contact Carrier at [email protected] or use the webform located here. You can also contact us at 1-833-617-0050. 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.

Annually California residents may request and obtain information that Carrier 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 Carrier shared this information in the immediately preceding calendar year. To obtain this information, please send an email message to [email protected] with “California Shine the Light Privacy Request” in the subject line as well as in the body of your message.

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.

Users of Apps’ Contact Notification Feature: User self-assessment responses and details of contacts with other user devices submitted, collected and/or utilized by the Apps’ COVID-19 Contact Notification feature (the “Contact Notification Data”) are held and used in an anonymized manner and are stored in LENELS2’s Microsoft Azure cloud instance. The Contact Notification Data is retained by the Apps for a period of one (1) month from the date collected, after which time it is automatically purged.  LENELS2 will not share Contact Notification Data with any 3rd party other than those needed to provide services in connection with the development, support and maintenance of the Apps.  The Contact Notification Data is only intended for use in connection with facility access management related to COVID-19 concerns and requirements and the Contact Notification Data will be used by LENELS2 for no other purposes. In particular, the Contact Notification Data can be used to restrict access of users to subscribing facilities who have self-assessed as COVID-19 positive and to send notifications of potential COVID-19 exposures within subscribing facilities to users who have come into direct contact with another user who has self-assessed as COVID-19 positive.

The Apps’ Contact Notification feature is a tool intended to help slow the spread of COVID-19 in indoor environments where the Apps are in use. A notification of a potential exposure does not necessarily mean you have or will develop COVID-19, but since you may have been exposed, there is a risk that you may develop the illness. The Apps’ Contact Notification feature is for informational purposes only, is not intended to be medical advice or a substitute for medical advice, diagnosis or treatment and should not be relied upon as such. Always seek the advice of your physician or other qualified health care provider with any questions you may have about COVID-19 or any other medical condition, and never disregard professional medical advice or delay in seeking it because of something you have been notified of, or not notified of, by the Apps.

Feature Availability: Not all Apps and Services features and options are available in all locations.  In particular, the Apps’ COVID-19 Contact Notification and indoor positioning features are not available outside North America.

How might LENELS2 change this Privacy Notice?

As LENELS2 expands and improves the Apps and Services, 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.  Substantive changes, if any, will be identified at the top of the Privacy Notice.

How can you contact LENELS2?

If you have any comments or questions about this Privacy Notice, LENELS2’s privacy practices in general, or to obtain information on the manner in which we or our service providers treat your Personal Information, please email [email protected].

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 be updated, corrected or removed, you should follow this link.

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Last updated on September 14, 2021.