Sensi Privacy Addendum to Copeland LP's global Privacy Notice
Last Revised: January 1, 2024
The disclosures within this Sensi Privacy Addendum supplement those found within Copeland LP’s global Privacy Notice (“Privacy Notice”). Please read the entire Privacy Notice and this entire supplemental privacy notice (“Sensi Privacy Addendum”) carefully before using our Sensi™ products, including Sensi Smart thermostats and Sensi Predict (the “Products”), and the related services, systems and software, including websites, mobile applications, portals, and social media applications (the “Services”). These disclosures will help you understand what data we collect, how we use and share it, and what your choices are with respect to that data. Capitalized terms in this notice have the same meaning as set forth in the Privacy Notice unless otherwise indicated.(“Privacy Notice”). Please read the entire Privacy Notice and this entire supplemental privacy notice (“Sensi Privacy Addendum”) carefully before using our Sensi™ products, including Sensi Smart thermostats and Sensi Predict (the “Products”), and the related services, systems and software, including websites, mobile applications, portals, and social media applications (the “Services”). These disclosures will help you understand what data we collect, how we use and share it, and what your choices are with respect to that data. Capitalized terms in this notice have the same meaning as set forth in the Privacy Notice unless otherwise indicated.
Although not part of this Sensi Privacy Addendum, your use of the Products and Services is subject to terms and conditions of the Sensi Terms of Service and the Sensi End User License Agreement.
CONTACTING US
If you want to exercise your data privacy rights as stated below or you have any questions about Sensi privacy practices, our contact information is as follows:
Email: [email protected]
Regular Mail: Comfort Control
Attention: Copeland General Counsel
8100 West Florissant Avenue
St. Louis, MO 63136
PERSONAL DATA COLLECTION
We may collect Personal Data, including Sensitive Personal Data, from you through your use of the Services, including Contact Information, Demographic Information, Analytical Information, location-based information and other information you choose to provide. If you choose not to submit Personal Data or location-based automation information, we may not be able to provide you with the full Services or Product capabilities.
To enable us to provide the Services or Product support, we will ask you to provide certain Personal Data when you create an account, access a Sensi portal, or download a Sensi mobile application, as either an owner of a Product or as an additional user or authorized controller granted access by or through the owner of the Product (“Additional User”). If you allow or authorize an Additional User to access your account, the Additional User may control and view your Personal Data, devices and content. Note that your Additional Users may add other Additional Users who all, collectively, will be associated with your account. Copeland LP is not responsible for the actions of your Additional Users. If location-based services are enabled in your account, you will be authorizing the sharing of your location data from your connected device and from the devices of your Additional Users. This data will be processed and pooled with other product data to enhance your Services and the Products.
We may also collect Personal Data when you provide it to us voluntarily, such as by filling out a form or survey; by registering an account and e-mail address with us; by choosing to allow location-based automation from your mobile device; by e-mailing us; by posting information on the Sensi portal; by posting on Sensi social properties; by reviewing a Product; or by contacting support. We may also collect Personal Data with your consent or as permitted or required by law.
HEATING, VENTILATION, AIR-CONDITIONING (“HVAC”) SYSTEM INFORMATION COLLECTION
As part of the Services, we may collect information about your HVAC system. This includes information such as temperature, thermostat settings, thermostat schedule(s), how you control the HVAC system, and the operation of your HVAC system. Some of the data we collect is relatively static, such as data about the heating and/or cooling system (for example, serial numbers and device IDs for devices in the HVAC system and the Sensi model and serial number). Other data we collect is more dynamic, such as information about current and past device usage levels or information about abnormal device functioning. We collect this data directly from you and the HVAC system, and transmit it through your network and/or Internet services. Our information collection may continue until you disconnect the Products and the Services are able to be cancelled or terminated. We augment the data with public data from third parties, such as local weather conditions. Note that if you do not allow us to collect this information, we may not be able to provide the full capabilities of Products and Services.
COOKIES
We use “cookies,” a small text file transferred to your device, along with similar technologies (e.g., internet tag technologies, web beacons and embedded scripts) to help provide you with a better, more personalized user experience. To learn more about how we use cookies and to change your cookie settings, please visit Copeland LP’s Cookie Notice.
Analyzing Sensi App Activity
We use a third-party activity analytics provider to enable us to monitor and improve the user experience on the Sensi app. This third-party activity analytics provider uses cookies and similar technologies to collect information, such as IP address, device information (e.g., operating system), and information on user behavior (e.g., screens visited, buttons clicked, limited information entered, and user taps).
HOW WE USE YOUR PERSONAL DATA AND HVAC INFORMATION
We use your information to provide Services to you and to operate and improve the Products and Services. In addition to the uses stated in the Privacy Notice section titled, “How We Use Your Personal Data”, such uses may also include providing technical support; sending you communications related to the Product or Service you purchased; making the Services easier to use; offering you partner products and services; and performing research and analysis aimed at improving our Products, Services and/or technologies. We may also use your information for other purposes with your consent or as permitted or required by law.
SECURITY
We maintain appropriate technical and organizational measures to protect your Personal Data and HVAC information. However, no method of Internet transmission or electronic storage is 100% secure or error-free, so it is not possible to guarantee absolute security of your Personal Data and HVAC information.
INTERNATIONAL DATA FLOW
Use of the Products and Services are authorized only in Canada and the United States of America. Some of our servers and service providers, including our affiliates, may be located outside of the United States of America and we may share your information with them for the purposes described above, including to provide technical support. The laws and privacy protections, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using Sensi in a region or country with laws governing data collection and use that differ from United States law, you consent to the transfer of your Personal Data to the United States and other countries where we, or our service providers, operate. Your information will be subject to the laws of the country in which our service providers are located, which laws may permit law enforcement, government and national security authorities to have access to your information in certain circumstances.
PERSONAL DATA SHARED WITH THIRD PARTIES
We may share your Personal Data as stated in the Privacy Notice. Additionally, if you sign up for products or services through us that are provided by third parties, or in which third parties are involved, we may share your Personal Data with those third parties as necessary to provide those products or services to you. If you or your Additional Users authorize the control of your Products by a third-party application, provider, software or other offering (such as a utility or energy company, Apple HomeKit, Amazon Alexa, or a similar offering) we do not and cannot control or be responsible for how the third party uses your Personal Data or any other information collected by the third party. We are not responsible for the content or the privacy practices employed by third parties. We encourage you to read the privacy policies of third parties before transmitting any Personal Data to them. We do not knowingly allow third parties to collect Personal Data about you through our Services, though we may share information we have collected as provided for in this Sensi Privacy Addendum. For example, when we collect information about your HVAC system, we may de-identify this data and aggregate it with the data from other users and use this for future analysis. We may share or publish this aggregated, anonymized data.
CALIFORNIA RESIDENTS
The following subsections replace the same subsections found within the ”California Residents” section of the Privacy Notice. For a description of your rights under the CCPA and CPRA as well as a complete description of our online and offline practices regarding the collection, use, disclosure and sale of Personal Information, including Sensitive Personal Information, pursuant to the CCPA and CPRA, please review our Privacy Notice. If you are a California resident, you may exercise certain rights regarding your California Personal Information, subject to certain exceptions and limitations, by clicking here.
(i) Right to Know About Personal Information Collected, Disclosed, or Sold
Collection of Personal Information
We currently collect and, in the 12 months prior to the “Last revised” date of this Sensi Privacy Addendum, have collected the following categories of Personal Information:
Identifiers (name, alias, postal address, online identifier, internet protocol address, email address, account name)
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
Telephone number
Geolocation data
Commercial information (records of products or services purchased, obtained or considered and other purchasing or consuming histories or tendencies) Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences and behavior.
The Personal Information is collected from California residents directly and from advertising networks, internet service providers, operating systems and platforms, and social networks. Not all categories of Personal Information are collected from each source.
In addition to the purposes stated above in the section “How We Use Your Personal Data and HVAC Information”, we currently collect, and have collected, the above categories of Personal Information for the following business or commercial purposes:
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of our Services and Products, and to improve, upgrade, or enhance same
Commercial purposes, such as inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure of Personal Information
The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the “Last revised” date of this Sensi Notice Privacy Addendum and, for each category, the category of third parties to whom the Personal Information was disclosed. We do not sell or share Personal Information, including Sensitive Personal Information, to third parties, including Personal Information or Sensitive Personal Information of minors under 16 years of age.
(ii) Right to Opt-Out of Sale or Sharing of Personal Information and Sensitive Personal Information
We do not sell or share Personal Information as it is defined in the CCPA or Sensitive Personal Information as it is defined in the CPRA.
CANADIAN RESIDENTS
The file containing your Personal Data and HVAC information will be electronically maintained on our servers or the servers of our service providers, who may be located outside of Canada. Our authorized employees, agents and mandataries who require access to your Personal Data and HVAC information to perform their job functions, will have access to this information. To request access to, or correction of, your Personal Data, or if you have any questions or concerns about how we handle your Personal Data, please write to us at the address provided above under the section Contacting Us. Quebec Residents: A French version is available upon request. La version française est disponible sur demande.
ACCESSIBILITY
We are committed to ensuring this Sensi Privacy Addendum is accessible to individuals with disabilities. If you wish to access this Sensi Privacy Addendum in an alternative format, please contact us as stated above under the section Contacting Us.
CHANGES
We may update this Sensi Privacy Addendum from time to time. We will notify you of any such changes, including when they will take effect, by updating the “Last revised” date above or as otherwise required by applicable law.
