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Applies to: Multi-Country
Revised: December 31, 2021

Residential Systems

The Lutron App and Lutron Connect App (“App”) lets you control the personal data provided by you or collected by Lutron when you use the App (“Data”). This Privacy Notice is intended to assist you in making informed decisions when using the App. Please take a moment to read and understand it. Please note that within this App you may be redirected to a Lutron website, in which case you should also review the privacy notices specific to that website.

This Privacy Notice explains the Data we collect from you and how we use that Data when you use the services available from the App.

We do not sell your personal data. Ever.
The primary purpose of collecting Data is to provide you with enhanced functionality when you control your lighting control system. To control your lighting system via the App you must also:

  1. Purchase a system bridge and connect it to the internet via a wired ethernet connection.

  2. Have a Wi-Fi or cellular internet connection to the device on which you installed the App (usually a smartphone or tablet computer).

 

What Data categories do we collect, for what purpose, and who do we share it with?

Category:Purpose:Disclosed to:
Personal Data/identifiers you provide as part of account setup information
  1. To allow you to access your account

  2. To allow Lutron to send you emails

  3. To identify your location (country)

  4. Connected system functionality.

Third-party providers, including:
  1. Cloud service providers

  2. Service providers that facilitate email communications from Lutron

Optional integrator functionality (such as Apple, Alexa)Third-party integrators – information only disclosed for services that you requested.
Optional timeclocking functionality/geolocation 
Technical lighting system information including electronic network and internet activityTo enable connected system functionalityThird-party providers, including:
  1. Cloud service providers

  2. Third-party integrators – information only disclosed for services that you requested

  3. We may share your system log files to assist with troubleshooting issues or provide technical assistance that you request

  4. Service providers that monitor for up-time reliability and system security

Commercial information for Lutron marketing programs targeted to professional installers (may require Contractor Mode use)

For professionally installed systems, Lutron shares commercial information with the installing contractor (such as number of devices installed). Additionally, we provide the installing contractor’s name (as provided by the installer) with the name of the owner of the lighting control system (typically the homeowner).

  1. Personal Data/identifiers you provide as part of account setup information:

    When you install a bridge and the App, you will need to establish an account with Lutron by providing an email address, password, and country. Also, if you have multiple homes, you may enter a name for each home. For heightened security, we do not recommend using the street address of your home(s).

    We use this Setup Information for the following purposes:
    1. To provide you with the ability to control your lighting control system with the App (combined with the lighting and technical information from the bridge – see below).


      We share your Data with third-party providers, primarily cloud service providers, to assist us in providing App functionality. If you have requested to integrate your Lutron system with a third party, we share your Data with that third party. See the section—"Your request to share Data with third-party systems” for more information.

      The following is required to be provided to European Union (“EU”) users: The service providers we use are located within the United States and their use of your Data is governed by the US Privacy Shield. The legal basis for our use of your Data for the purposes in this section is to perform our obligations in accordance with the contract that we have with you, in this case to provide the functionality for your App to control your lighting control system.

    2. To email you important service updates, such as account password reset requests, information on security updates, technical support information, etc.

      We may contact you by email for service and security-related notifications. An example of a security-related notification is an email confirming your account initiation, password changes, and similar changes that allow you to monitor any unauthorized access to your account. Additionally, we may send you a product support email approximately 1 week after your account is initiated to provide you with customer support contact information. Because this information is provided for App functionality, you cannot opt out of receiving these service and security related emails.

      We share your Data with third-party providers that assist us in delivering these emails to you.

      The following is required to be provided to EU users: The service providers we use are located within the United States and their use of your Data is governed by the US Privacy Shield. The legal basis for our use of your Data for the purposes in this section is to perform our obligations in accordance with the contract that we have with you, in this case to provide security and service-related updates from us.

    3. We collect the name of the country where your system will be used to assist us in complying with country-specific laws such as data-privacy and email marketing rules.


      The following is required to be provided to EU users: As country information does not include personal data, a legal basis is not required.

  2. Technical lighting system information collected from the bridge including electronic network and internet activity.

    We collect technical information from the bridge to enable the system to function. Examples of this information include: devices you have linked to your Lutron system such as dimmers, switches, remote controls, sensors, room names, scene details, timeclock event details, Sonos ® speaker names, integration details (such as identifiers for third-party products that are part of any Third-party interoperability you have enabled), Lutron window shades, network configuration information and the MAC ID of the bridge.

    In addition to collecting technical information from the bridge, we also regularly push firmware updates to the bridge for both functionality and security updates.

    We use the lighting and technical information from the bridge for the purpose of providing you with the service of having the App control your lighting control system and to support connected system functionality.

    We share your Data with third-party providers, primarily cloud service providers, to assist us in providing the App and bridge functionality for your lighting control system. If you have requested to integrate your Lutron system with a third party we share your Data with that third party. See the section—"Your request to share data with third-party systems” for more information.

    The following is required to be provided to EU users: The service providers we use are located within the United States and their use of your Data is governed by the US Privacy Shield. The legal basis for our use of your Data for the purposes described in this section is to perform our obligations in accordance with the contract that we have with you, in this case to provide the functionality for your App to control your lighting system and connected system functionality.

  3. Information from the App and the device the App is installed on.
    1. We collect information from the App to provide the functionality you have requested. Examples of this information include sending us your button presses and similar aspects of the App functionality to initiate changes to lighting levels, initiate timeclock events, etc. Additionally, we collect information from the device the App is installed on such as MAC ID of the device and the operating system version of the device.


      A note about Timeclocking/Scheduling: When setting up your system you will be asked for permission to access your device’s location (a one-time snapshot of the location of your device) and time zone of your device to establish the general location of the bridge and to provide timeclocking/scheduling functionality.

      We obtain only the general location (within a .6 mile/1 km area) of the bridge, such as your city. The exact location is not recorded by us as it is not required to provide timeclocking/scheduling functionality. Timeclocking/scheduling allows you to program your system based on your sundown and sunrise times. For example, you may program an outside light to turn on 30 minutes after sunset and turn off 30 minutes before sunrise. By providing the general location of the bridge you allow the system to automatically adjust as sunset and sunrise times change throughout the year including any daylight savings time.

      If you choose not to give the App location permissions from your device, the bridge location will be assumed to be Lutron headquarters in Coopersburg, Pennsylvania, USA

      Who do we share your Data with for this purpose?

      We share your Data with third-party providers, primarily cloud service providers, to assist us in providing App functionality for your lighting control system. Additionally, if you have requested to integrate your Lutron system with a third-party we share your Data with that third party. See the section—"Your request to share data with third-party systems” for more information.

      The following is required to be provided to EU users: The service providers we use are located within the United States and their use of your personal data is governed by the US Privacy Shield. The legal basis for our use of your Data for the purposes described in this section is to perform our obligations in accordance with the contract that we have with you, in this case to provide the functionality for your App to control your lighting system.

    2. We use your Data to assess system up-time performance and to monitor for security threats. Also, we use Data in an aggregated manner to enable us to monitor up-time system availability, whether we have adequate bandwidth for the lighting control system to operate, etc.


      The following is required to be provided to EU users: The service providers we use are located within the United States and their use of your personal data is governed by the US Privacy Shield. The legal basis for our use of your Data for the purposes in this section is to perform our obligations in accordance with the contract we have with you.

  4. For users in the United States, we use commercial information and electronic network/internet activity (obtained from Account Setup Information, Lighting system technical information collected from the bridge, and Information from the App) internally within Lutron for product research and development, marketing, and analytical purposes. The processes we have in place allow us to look at users generally while not identifying any specific person.
     
  5. Your choices:


    The App settings provide you with the choice to:

    1. Enable Geofencing. To enable geofencing functionality, you provide us with the relative location of your device. Geofencing gives you the ability to program your lighting control system to activate based on your device’s location. Examples of geofencing include turning the garage lights on as you arrive home and turning interior lights off when you leave.


      If you enable geofencing, we receive a notice from your device as to the relative location of your device compared to the lighting control system location noted in the App. We do not log or track the location of your device, but rather we receive a signal from your device notifying us of its proximity to the lighting control system.

      We share your Data with third-party providers, primarily cloud service providers, to assist us in providing the geofencing functionality. Additionally, if you have requested to integrate your Lutron system with a third party, we share your Data with that third party. See the section—"Your request to share data with third-party systems” for more information.

      The following is required to be provided to EU users: The service providers we use are located within the United States and their use of your personal data is governed by the US Privacy Shield. The legal basis for our use of your Data for the purposes described in this section is your consent.

    2. Share App usage and diagnostic information with us. To toggle this feature in the “Send Usage Data”.


      The following is required to be provided to EU users: If you enable this functionality, we use your Data for understanding how the App is used and to diagnose problems with the App. We hope you agree to share this information as it helps us build better products and Apps. As examples of how we use this information: we may use this information to better understand what functions of the App are used the most and to learn about App processing errors so that we can focus on software development in these areas. We may also collect the type and number of devices connected to your lighting control system so that we can focus our product development and make informed business decisions.

      We share this information with third-party providers who log and provide App usage and diagnostic information to us.

      The following is required to be provided to EU users: The legal basis for our use of your Data for the purposes described in this section is your consent.

  6. Getting help from us:
     

    Within the App, you may request assistance from us by sending system log files from the App to us. These log files contain a full copy of your lighting control system Data, including scene and button names to enable full troubleshooting. If you provide system log files to us, we use this Data for the purpose of diagnosing and responding to your inquiry requesting assistance. We retain log files you send to us for up to 1 year after we have addressed your request for assistance.

    The following is required to be provided to EU users:

    We may share your system log files with Lutron United States operations and Lutron India operations (Lutron GL Sales and Services Pvt. Ltd.). Additionally, for select technical issues, we may share your log files with a contractor located in India.

    The legal basis for our use of your Data for the purposes described in this section is to perform our obligations in accordance with the contract that we have with you, in this case to respond to your request for assistance.

Your request to share data with third-party systems

Your lighting control system can inter-operate with many third-party systems such as Apple® HomeKit™, Google Assistant™, Amazon Alexa™, etc. It is your choice to permit these third-party systems to access your lighting control system. Also, by requesting such third-party interoperability, you are requesting an ongoing transfer of your Data to the third-party system. Each third-party has varying requirements of the quantity of your Data needed for their interoperability to function. Please be aware that some third parties require a complete set of your Data be continuously transferred for their interoperability to function.

To initiate the interoperability, you are generally required to enroll via the third party’s system. By enrolling, you are authorizing Lutron to share your Data with the third party. Any Data we provide to the third party at your request is not covered by this Privacy Notice as that data is no longer under our control. Any Data that you request us to provide to a third party is controlled by that third party’s privacy policy.

For some third-party systems you may disable interoperability within the App. (Location in App: Settings-Advanced-Integrations). If you wish to disable interoperability, we also recommend you do so by selecting the appropriate controls within that third-party system.

How to contact us to: request a copy of your data, request to have your personal data erased, or for other privacy inquiries.

  1. www.lutron.com/DataPrivacyRequest

  2. DataPrivacy@Lutron.com

  3. 1 (844) LUTRON1

For security reasons, we will need to verify that the person initiating a data request is authorized. As you must have an account for this App to function, upon our receipt of a Data request we will advise you to send certain information from within the App while you are logged into your account. We must receive the requested information within the provided time period in order for us to initiate your Data request. Should you use an authorized agent to initiate a data request on your behalf, you will need to coordinate the sending of the required account verification information to us with your authorized agent.

If you are contacting us via email or telephones, please be sure to include the nature of your request (e.g. request a copy of your data, request data erasure, etc.). Initiating a request will not impact your service level of the operation of your lighting controls system.

If you request erasure of required operational data, certain functionality provided by the App and bridge will be lost such as: the ability to use the App to remotely control your lighting control system, timeclocking, and third-party integrations. If you request erasure of your account, you can later create a new account and re-use the existing lighting control system hardware, however you will need to reprogram your system.

The following is required to be provided to EU users regarding Data access and rights:

You have the following rights in relation to the Data we hold about you:

  1. Your right of access. If you ask us, we’ll confirm whether we’re processing your Data and, if so, provide you with a copy of that Data (along with certain other details).

  2. Your right to rectification. If the Data we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your Data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Data with so that you can contact them directly.

  3. Your right to erasure. You can ask us to delete or remove your Data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your Data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your Data with so that you can contact them directly. Upon deleting your Data, backups of personal information may remain for a reasonable time with us before they are deleted. We may need to retain certain Data if required to do so for legal reasons. To remove the possibility of further Data being sent to us, you should remove the ethernet cable from your bridge and uninstall the App from your device.

  4. Your right to restrict processing. You can ask us to “block” or suppress the processing of your Data in certain circumstances such as where you contest the accuracy of that Data or you object to us processing it. It won’t stop us from storing your Data though. We’ll tell you before we lift any restriction. If we’ve shared your Data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we have shared your Data with so that you can contact them directly.

  5. Your right to data portability. You have the right, in certain circumstances, to obtain Data you’ve provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. We will provide the Data in a comma separated value (CSV) format to you via email upon your request.

  6. Your right to object. You can ask us to stop processing your Data, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your Data, except if we can demonstrate compelling legal grounds for the processing, or processing your Data for direct marketing.

  7. Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

  8. Your right to withdraw consent. If we rely on your consent as our legal basis for processing your Data, you have the right to withdraw that consent at any time.

  9. Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, EU users can report it to the data protection authority within your country.

How long do we keep your Data & how do we protect it?

Provided you continue to use the lighting control system, we will retain your Data to provide the functionality you have requested. If your App or bridge is not used for 5 years, we will start the process to remove your account from our systems. You will receive at least 2 emails advising you to log into your account and/or use your system in order to keep your account active. If we close your account due to inactivity you will need to re-enroll your bridge to re-enable functionality. Note that if your Data is only needed for a shorter period, we may delete it.

We take security very seriously and we follow industry best practices around securing Data, monitoring for potential abuse, and updating systems.

About us

Lutron Electronics Co., Inc. is headquartered in Coopersburg, Pennsylvania, in the United States. We are approximately 60 miles north of Philadelphia. We are an industry leading manufacturer of lighting control systems and have been in business for more than 50 years.

Contact us at: DataPrivacy@Lutron.com

The following is required to be provided to EU users:

When we transfer personal data from the EU to the United States and India, we use contractual clauses process approved by the European Commission.

For EU regulatory purposes, the data controller is:

Lutron Electronics, Co., Inc.
Attn: Data Privacy
7200 Suter Road
Coopersburg, PA 18036 USA