Revised: December 31, 2022

Energi Savr Node and Grafik Eye Privacy Notice

Lutron respects your privacy and provides you with control of your personal data. This Privacy Notice is intended to assist you in making informed decisions when using the Energi Savr Node application ("ESN App"), module ("ESN Module"), Grafik Eye Single Unit Programmer application ("Grafik Eye App"), or module ("Grafik Eye Module"). Please take a moment to read and understand it. Please note that within the ESN App and Grafik Eye App you may be redirected to a Lutron website; in that case you should also review the privacy notices provided for that website.

No data is automatically transmitted to Lutron from the ESN App, ESN Module, Grafik Eye App, or Grafik Eye Module, any data files produced by the ESN App or Grafik Eye App can be shared at the user's discretion or, in the case of the ESN Module or the Grafik Eye Module, by your Energi Savr Node or Grafik Eye dealer or installer. The primary purpose of collecting data is so that we can provide customer and troubleshooting assistance with the ESN App or Grafik Eye App, or with the ESN Module or Grafik Eye Module, should either be needed.

For the ESN App to function you must purchase an ESN Module which, in turn, must be connected to a router via a wired Ethernet connection or via an Energi Savr Node Ethernet Interface. Additionally, the mobile device on which you have installed the ESN App on must have Wi-Fi connection capability.

For Grafik Eye App to function you must also purchase the Grafik Eye Module which, in turn, must be connected to a computer running the Grafik Eye App via either a USB-Mini or USB-Micro cable, depending upon the model of the Grafik Eye Module that you are using.

What information do we collect?

The following information may be shared with Lutron when provided by either you, your Energi Savr Node dealer/installer, or your Grafik Eye dealer/installer in the following circumstances:

ESN Setup Information and Diagnostic Data
Setup information and diagnostic data will be automatically written to a file on your mobile device as you use the ESN App to commission your ESN Module. This data may include technical information about your mobile device, technical information about other Lutron devices connected to your ESN Module, and any programming information input into the ESN App. Some examples of this data include the version of mobile operating software your mobile device is running (e.g. iOS for Apple devices), the names of other Lutron devices connected to your ESN Module, and the names of areas and zones that you program.

Lutron uses this setup information and diagnostic data for the following purposes:
- If you or your dealer provide system log files to us for troubleshooting assistance, we will use this information for the purpose of providing solutions to improve/fix your lighting control system.
Lutron does not provide this information to third parties and Lutron does not sell this information.

The legal basis for use of your personal information is to perform our obligations in accordance with any contract that we may have with you, in this case to provide you troubleshooting support.
Backup of System Information
After an ESN Module or Grafik Eye Module is commissioned, it is possible to save a backup of its programming using the ESN App or the Grafik Eye App. This backup will include any programming you've done to the ESN Module or Grafik Eye Module, which will include the names of areas, zones, scenes, and presets.

Lutron uses this backup data for the following purposes:
- To maintain a backup of your ESN Module or grafik Eye Module in order to provide you support in the event that your system becomes damaged or corrupted.
- To be able to quickly assess system issues and provide solutions to improve/fix your lighting control system should an issue arise.
Lutron does not provide this information to third parties and Lutron does not sell this information

The legal basis for use of your personal information is to perform our obligations in accordance with any contract that we may have with you, in this case to provide you troubleshooting support.
Grafik Eye Timeclocking
When setting up your Grafik Eye Module you may be asked to provide the geographic location. We use this location to provide you with timeclocking functionality. You can choose to enter either the city/state or the latitude and longitude of the device. Timeclocking allows you to program your system based on your sundown and sunrise times.

For example, you may program an outside light to turn on thirty (30) minutes after sunset and turn off thirty (30) minutes before sunrise. By providing the location of the Grafik Eye you allow the system to automatically adjust as sunset and sunrise times change throughout the year. If you choose to not enter the Grafik Eye location into the App the Grafik Eye will use the default location of Philadelphia in Pennsylvania.

Lutron does not provide this information to third parties and Lutron does not sell this information.

The legal basis for use of your personal information is to perform our obligations in accordance with any contract that we may have with you, in this case to provide you with time clocking functionality.

How to Access Your Data and Your Rights

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

Your right of access. If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details).
Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information 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 personal information with so that you can contact them directly.
Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information 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 personal information with so that you can contact them directly. Upon deleting your personal information, backups of personal information may linger for a bit with us before they are deleted. Also, we may need to retain certain data if required to do so for legal reasons.
Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information 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’ve shared your personal information with so that you can contact them directly.
Your right to data portability. You have the right, in certain circumstances, to obtain personal information you’ve provided us with (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 information in a common industry format to you via email upon your request.
Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing
Your rights in relation to automated decision-making and profiling.¹ 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.
Your right to withdraw consent.¹ If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
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, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

To request a copy of your data, request to have your personal data erased, or other privacy inquiry contact us at:

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

dataprivacy@lutron.com

Again, please be sure to include the nature of your request.

¹For Users in the EU we are required to provide this information.

How long do we keep your personal information & how do we protect it?

Lutron takes security very seriously and we follow industry best-practices around securing data, monitoring for potential abuse, and updating systems. All information that Lutron can collect from the ESN App, ESN Module, Grafik Eye App, or Grafik Eye Module will be stored in servers based in the United States and accessible only by qualified Engineers, Technicians, and Technical Support.

We retain your personal data only for as long as is necessary for our relationship with you, in accordance with our retention policies and in accordance with applicable laws. We do not collect more personal data than we need to fulfil our purposes stated in this privacy policy and we will not retain it for longer than is necessary.

For instance, if you contact Lutron for assistance, any e-mail correspondence related to that issue will be deleted upon resolution of the issue.

International transfers of personal data

International transfers of personal data<sup style="vertical-align: super;">1</sup>

Some of our group entities and service providers are located outside of the European Economic Area (EEA), in the United States or India, for instance. We may share this information with such parties, and with a contractor located in India, for select technical issues.

Accordingly, If you are an EU national and reside in the EU, or are non-EU national residing in the EU, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

where we use providers based in the US, we may transfer your personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US; or
where we use certain service providers based outside of the US, we may transfer your personal data in accordance with EU data protection law requirements by using standard contractual clauses that have been approved by the European Commission.

Such a transfer may also be necessary in order to perform a contract with you/fulfil your request and/or through obtaining your explicit consent.

¹For Users in the EU we are required to provide this information.

About us

Lutron Electronics Co., Inc. is headquartered in Coopersburg, Pennsylvania, 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.

For EU regulatory purposes, the controller is¹:

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

and our EU representative is:
Lutron EA Ltd.
4th Floor, 52 Leadenhall Street
London EC3A 2EB England

¹For Users in the EU we are required to provide this information.

Changes to this Privacy Notice and your duty to inform us of changes

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.