Brightlayer Privacy Notice

Last Updated: January 9, 2025

The End User License Agreement for Product Software and the Terms of Services for Brightlayer Cloud Services, as applicable, are incorporated by reference into this Privacy Notice.

Eaton Corporation (“Eaton,” “us,” “we,” or “our”) owns and operates the Product Software and/or Brightlayer Cloud Services, including mobile applications, products and services related therein (collectively, the “Services”). Eaton, as the data controller, is committed to protecting the privacy of those who use the Services.  Please read this Privacy Notice carefully. If you do not agree with our policies and practices, do not download, install or operate the Services, do not access or use the Services, and do not interact with any other part of the Services. 

Applicability: This Privacy Notice covers only the Services identified above and does not apply to information that you may send us by other means or related to other Eaton products or services, including websites. Whenever you interact with Eaton or the Services on behalf of another individual or entity, such as by providing or accessing Personal Data about another individual, you represent that you have the authority to do so. You shall have sole responsibility for any violation of privacy laws as a result of a failure to obtain any necessary consent from such individual/entity.

Changes: Eaton may update this Privacy Notice from time to time. Please check this Privacy Notice periodically for updates. If any of the changes are unacceptable to you, you should cease using the Services. When required, we will notify you of any changes to this Privacy Notice and seek affirmative consent from you, by email (if we have a valid email address to use).

What Information Do We Collect?

Personal Data (“Personal Data”) is any information relating to an identified or identifiable natural person (“Data Subject”).  We do not sell Personal Data.

Sources of Personal Data:

We collect information about you and how you use the Services in several ways, including:

• Information you provide to us directly. We collect the information you provide to us directly, such as when purchasing or registering to use the Services, signing up for offers, or communicating with us.
• Information collected or inferred from your use of the Services. We collect information about the Services and how you use them, such as information collected automatically when you use or download a mobile application, or otherwise interact with the Services.
• Information from third parties. We receive information about you and your use of the Services from third parties, such as from third party service and content providers, companies that provide or sell lists of potential purchasers, and other Services users.

Data Security and Retention

Eaton maintains reasonable security procedures and technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, loss, disclosure or use of personal data we handle. When handling your Personal Data for our business functions, Eaton will limit access to your Personal Data to authorized persons and trusted third parties who have a reasonable need to know the information in order to perform our Services who are bound by confidentiality obligations. While Eaton takes the issue of protecting your Personal Data seriously, you should exercise discretion in what information you disclose and/or transmit through the Services. Eaton cannot guarantee that information sent over the Internet is fully secure, and therefore the transmitted information may be intercepted by others before it reaches Eaton. Eaton is not responsible for the security of information sent over the Internet.

Eaton retains Personal Data only for as long as necessary to fulfill the stated purpose for which the Personal Data was collected or otherwise processed, and thereafter only for legitimate legal or business purposes. We will delete Personal Data as soon as the respective purpose for its use is complete and no legal obligation to retain such data exists. 

Children’s Privacy

The Services are intended for individuals 18 years of age and older. The Services are not directed at, marketed to, nor intended for, children under 18 years of age. Eaton does not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us.

Collection, Disclosure, and Sharing of Personal Data

Purposes for the Collection, Processing, and Disclosure of Sensitive Personal Data

Subject to your consent where required by applicable law, we collect, process, and disclose Sensitive Personal Data for purposes of: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual.  We do not use Sensitive Personal Data beyond these purposes.

Additional Information for U.S. Residents

This section supplements the above Privacy Notice and provides additional details including your privacy rights. In the event of a conflict between the information in this Privacy Notice and the rest of the Privacy Notice, this section will govern. We do not knowingly “sell” or “share” (for purposes of cross-context behavioral or targeted advertising) Personal Data, including Sensitive Personal Data, of minors under 16 years of age.

Individual Requests

Subject to applicable law, you may make the following requests:

1. You may request to know whether we process your Personal Data, and to access such Personal Data.
   a. If you are a California resident, you may request that we disclose to you the following information:
        i. The categories of Personal Data we collected about you and the categories of sources from which we collected such Personal Data;
        ii. The business or commercial purpose for collecting, selling, or sharing Personal Data about you;
        iii. The categories of Personal Data about you that we sold or shared (as defined under the applicable privacy law) and the categories of third parties to whom we sold or shared such Personal Data; and 
        iv. The categories of Personal Data about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Data (if applicable).
   b. If you are an Oregon resident, you may also request that we disclose to you the following information:
        i.  The categories of Personal Data we process about you; and
        ii.  The third parties to whom we have disclosed Personal Data.
2. You may request to correct inaccuracies in your Personal Data.
3. You may request to have your Personal Data deleted.
4. You may request to receive a copy of your Personal Data, including specific pieces of Personal Data, and, where applicable, to obtain a copy of the Personal Data you provided to us in a portable format.
5. You may request to opt out of the “sale” of your Personal Data.
6. You may request to opt out of targeted advertising, including the “sharing” of your Personal Data for purposes of cross-context behavioral advertising.

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law.  Eaton does not “sell” any Personal Data collected in use of the Services for any purpose, including Targeted Advertising or purposes of cross-context behavioral advertising.

To make a request under #1-#4, you may send an email to dataprotection@eaton.com, use this online form, or for California Residents only call +1-800-386-1911.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Data subject to the request. We may need to request additional Personal Data from you, such as name, email address, and mailing address, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Data.

As described above personal information we collect from consumers might be shared for business purposes with third parties. We have listed above all of the categories of personal information which may be disclosed for business purposes in the past 12 months from the date this Privacy Notice was issued.

Appeal Process

If you are a resident of Colorado, Connecticut, Montana, Oregon, Texas, or Virginia and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via dataprotection@eaton.com.

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section above entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section above entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

Contact Info/Your Choices

If you have questions regarding this Privacy Notice, please contact Eaton at:

Eaton
Attention: Global Data Protection and Privacy Office
1000 Eaton Boulevard
Cleveland, Ohio 44122
dataprotection@eaton.com

To opt-out of receiving promotional email messages from us, please click on the "Unsubscribe" link contained at the bottom of each email or by contacting us using the information above.

Additional Information For Residents of European Economic Area (EEA)

This section applies if you are an EEA data subject. In the event of a conflict between information in this section and the rest of the Privacy Notice, this EEA Section will govern. 

• Access. You have the right to confirm with us if your Personal Data is being processed and certain other information about that processing.
• Rectification. You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.
• Objection. You have the right to object to the processing of your Personal Data for compelling and legitimate reasons. In addition, you have the right to object at any time if your Personal Data is processed for direct marketing purposes.
• Portability. You may receive Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to others.
• Restriction. You may request to restrict processing of your Personal Data.
• Erasure. You may request to erase your Personal Data.
• Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence.
• Right to refuse or withdraw consent. Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.
• Right not to be subject to automatic decision-making, including profiling.

If you have questions about exercising any of your rights or whether they apply to a particular processing activity, you may contact us at: dataprotection@eaton.com.

Our legal basis for collecting and using the Personal Data as data controllers will depend on the Personal Data concerned and the specific context in which we collect it. In many cases, we will process Personal Data about you using the following legal basis:

• Legitimate interest – we process Personal Data to meet our legitimate business interests, such as to develop and improve our solutions, support our sales and business operations, and secure our systems, facilities and personnel.
• Legal obligation – we process Personal Data to comply with applicable laws and regulations. 
• Performance of Agreement – we process Personal Data in order to perform or fulfill our obligations under an agreement with you or the entity with which you are affiliated. 
• Consent – We may process your Personal Data based on consent. For example, if we want to send you a marketing communication, we will seek your consent separately at the time of collection. You may withdraw your consent at any time by contacting us at dataprotection@eaton.com.
  
  

International Transfers of Your Personal Data

By using the Services or providing Personal Data to Eaton, your Personal Data is transferred to the United States. If you are not a resident of the United States, your country’s laws governing data collection and use may differ from those in the United States. For example, the data protection laws of the United States have not been found by the European Commission to provide the same level of protection as EU data protection law. Transfers to countries outside the European Economic Area (“EEA”) take place using an acceptable data transfer mechanism, such as the EU Standard Contractual Clauses, Your consent or on the basis of permissible statutory derogations. Please contact dataprotection@eaton.com, if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.