Trane Technologies Company, LLC (“Trane Technologies”) respects individual privacy and values the confidence of its customers, employees, vendors, consumers, business partners and others. Trane Technologies strives to collect, store, process and distribute Personal information in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. This Data Protection and Privacy Policy (the "Policy") sets forth the privacy principles that Trane Technologies follows with respect to the collection, use and transfer of Personal information on the following US based Sites and Mobile Applications:
Trane Technologies has a Global Data Protection Officer who assists in ensuring compliance with this Policy. Trane Technologies educates its employees concerning compliance with this Policy and has self- assessment procedures in place to assure compliance. Trane Technologies’ Global Data Protection Officer Makila Scruggs and its Global Privacy Office are available to any of its valued employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Relevant contact information is provided herein.
This Policy applies to all Personal information received by Trane Technologies at the sites listed above. This includes Personal Data in any format including electronic, paper or verbal.
Trane Technologies collects, stores, and processes Personal information from customers, prospective customers, consumers, vendors, professional advisers and consultants, distributors, dealers, suppliers business partners and others, such as name, and business contact information. This information may be maintained at its corporate offices in Davidson, North Carolina, or at other Trane Technologies facilities, and its authorized agents, consistent with local legislation. Trane Technologies collects this Personal information for, among other things, legitimate business reasons such as processing and fulfilling orders; customer service; the provision of services or products to Trane Technologies, product, warranty and claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; marketing (as opted into where required); internal marketing research; safety and performance management; financial and sales data. All Personal information collected by Trane Technologies will be used for legitimate business purposes consistent with this Policy.
Trane Technologies may process and disclose Personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which a Trane Technologies business is acquired by or merged with another business, or sells, liquidates, or transfers all or a portion of its assets.
Trane Technologies also may process or disclose Personal information as is reasonably necessary or legally required on important public interest grounds, to respond to lawful requests by public authorities (including to meet national security or law enforcement requests), to meet governmental reporting or records requirements, or for the establishment, exercise or defense of legal claims by Trane Technologies or other companies within its corporate group.
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that processes Personal information provided by Trane Technologies to perform tasks on behalf of or at the instruction of Trane Technologies.
"Trane Technologies" means Trane Technologies, its subsidiaries, divisions and groups, with brands such as Trane and Thermo-King.
""Personal information" means any information or set of information that identifies or could be used by or on behalf of Trane Technologies to identify an individual. Personal information does not include information that is anonymized, or publicly available information that has not been combined with non- public Personal information.
"Sensitive Personal information" means Personal information that reveals race, ethnic origin, trade union membership, political opinions, or religious or philosophical beliefs, that concerns health or sex life, or that contains criminal records. In addition, Trane Technologies will treat as Sensitive Personal information any Personal information received from a third party where that third party treats and identifies the Personal information as sensitive.
Trane Technologies commits to subject the Personal information covered by this policy to the following principles:
(1) NOTICE: Where Trane Technologies collects Personal information directly from individuals, it will inform them about the purposes for which it collects, stores and processes Personal information about them, the types of non-Agent third parties to which Trane Technologies discloses that information, and the choices and means, if any, Trane Technologies offers individuals for limiting the use and disclosure of their Personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal information to Trane Technologies, or as soon as practicable thereafter, and in any event before Trane Technologies uses the information for a purpose other than that for which it was originally collected.
(2) CHOICE: Trane Technologies will offer individuals the opportunity to choose (opt-out) whether their Personal information is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
If collected, Trane Technologies will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of Sensitive Personal information, to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Trane Technologies will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
(3) DATA INTEGRITY AND PURPOSE LIMITATION: Trane Technologies will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Trane Technologies will take reasonable steps to ensure that Personal information is relevant to its intended use, accurate, complete and current.
(4) ACCOUNTABILITY FOR ONWARD TRANSFER: Trane Technologies uses third-party Agents to assist us in accomplishing the purposes described in this Policy, for example to support our customers, perform technical operations, and store and transmit data. Trane Technologies will confirm that any third party to which it discloses Personal information will appropriately safeguard the privacy of that Personal information. Examples of appropriate privacy safeguards include: a contract obligating the third party to provide at least the same level of protection as is required by the relevant privacy principles or applicable standards, the third party being subject to applicable data protection law, or the third party being subject to another European Commission adequacy finding. Where Trane Technologies has knowledge that a third party is using or disclosing Personal information in a manner contrary to this Policy, Trane Technologies will take reasonable steps to prevent or stop the use or disclosure. Trane Technologies holds third parties to which it discloses Personal information accountable for maintaining the trust our employees and customers place in the company.
(5) ACCESS AND CORRECTION: Upon request, Trane Technologies will grant individuals reasonable access to Personal information that it holds about them. In addition, Trane Technologies will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their Personal information can do so by contacting their local Human Resources Representative.
(6) SECURITY: Trane Technologies will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Trane Technologies protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. Trane Technologies limits access to Personal information and data to those persons in Trane Technologies organization, or as Agents of Trane Technologies, that have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have been granted access to Personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.
Suppliers, vendors and other third parties shall report any data breaches or potential data breaches of Personal information by completing the Data Breach Incident Form.
(7) RECOURSE, ENFORCEMENT AND LIABILITY: Trane Technologies will conduct compliance audits of its relevant privacy practices to verify compliance with this Policy and the relevant privacy principles. Any employee that Trane Technologies determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.
Any questions or concerns regarding the use or disclosure of Personal information should be directed to the Trane Technologies Global Privacy Office at the address given below. Trane Technologies will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy.
Trane Technologies sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others. Trane Technologies recognizes the importance of maintaining the privacy of Personal information collected through websites that it operates. Trane Technologies' sole purpose for operating its websites is to provide information concerning products and services to the public. In general, visitors can reach Trane Technologies on the Web without revealing any Personal information. Visitors on the Web may elect to voluntarily provide Personal information via Trane Technologies websites but are not required to do so. Trane Technologies collects information from visitors to the websites who voluntarily provide Personal information by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The Personal information voluntarily provided by website users is contact information limited to the user's name, home and/or business address, phone numbers and email address. Trane Technologies collects this information so it may answer questions and forward requested information. Trane Technologies does not sell this information. (See our California Consumer Privacy Notice for further clarifications on “selling” activities as defined under the California Consumer Privacy Act)
Trane Technologies may also collect anonymous information concerning website users through the use of "cookies" in order to provide better customer service. "Cookies" are small files that websites place on users' computers to identify the user and enhance the website experience. Company personnel periodically audit Trane Technologies' commercial websites to determine what cookies are used on each. The cookies used are typically not intrusive and are not typically connected to visitors' contact or other identifiable information. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. Visitors can learn how to control or delete cookies used on Trane Technologies' websites by visiting the About Cookies website for detailed guidance. If visitors do suppress the website cookies, however, some areas of Trane Technologies' websites may not function properly.
The table below describes the cookies used on Trane Technologies website.
We use a session cookie that lasts for the duration of your visit to our site and is used for load balancing.
User data is not linked to any of your contact information.
Google Analytics - we use this to understand how the site is being used in order to improve the user experience. User data is not linked to any of your contact information.
You can find out more about Google's position on privacy as regards its analytics service.
Adobe Analytics - we use this to understand how the site is being used in order to improve the user experience. User data is not linked to any of your contact information.
You can find out more about Adobe's position on privacy as it regards its analytics service.
Users have the preference to set-up geofences which allows the tracking of location and movement while using the Mobile Applications. When geofencing is enabled on the mobile app, the user must manually grant Locations services for the app in their phone. When granting the location permission we Trane Technologies collects the precise, real-time geo-location of the mobile device to determine if the phone is inside or outside of a given geofence. Users can update this location permission by managing their Location Services preferences through the settings of their mobile device.
Few, if any, of Trane Technologies' websites/applications are directed toward children. Nevertheless, Trane Technologies is committed to complying with applicable laws and requirements, such as the United States' Children's Online Privacy Protection Act ("COPPA"). The intended audience for the Sites/ Applications covered by this policy are individuals 18 years or older.
Trane Technologies websites may contain links to other "non-Trane Technologies" websites. Trane Technologies assumes no responsibility for the content or the privacy policies and practices on those websites. Trane Technologies encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of Trane Technologies.
Several US States have enacted Privacy regulations that provide specific rights to individuals including the California Consumer Privacy Act of 2018 (as amended November 2020) (“CCPA”) (Consumers, employees/applicants and B2B Customers) Additional states have passed laws extending similar privacy rights to their consumers. We use this privacy notice to make disclosures required by these state laws. The information contained in the Privacy Statement of Trane Technologies and its subsidiaries (collectively, “we,” “us,” or “our”). Please note that as the rules implementing some of these laws are finalized, we will continuously update our processes, disclosures, and this notice.
Information We Collect
In the chart below, we outline the categories of personal information we collect, the sources of the personal information, our purposes of processing, and the categories of recipients with whom we provide the personal information.
| Category of Personal Information | Sources | Purposes of Processing | Recipients |
|---|---|---|---|
| Identifiers: A real name, alias, postal address,Internet Protocol address, email address, account name, or other similar identifiers where applicable. | Individuals (customers) B2B partners where applicable) | Provide and support our products and services; respond to questions; help, secure, and troubleshoot; and marketing (where consent is obtained) | Service providers and user-directed entities |
| Demographic Information: Use provided name, physical characteristics or description, address, telephone number, debit card number, or any other financial information, where applicable. Some personal information included in this category may overlap with other categories. | Individuals (customers, B2B partners as applicable) | Provide and support our products and services; respond to questions; help, secure, and troubleshoot; and marketing (where consent is obtained), review employment applications, offer and facilitate employment, benefits, etc. | Service providers and user-directed entities |
| Commercial information: Information about Products or services purchased, obtained, or considered, or other purchasing or consuming histories related to our products and services | Individuals (customers), B2B partners as applicable) | Provide and support our products and services; respond to questions; help, secure, and troubleshoot; and marketing (where consent is obtained), | Service providers and user-directed entities |
| Device data: Data obtained from Trane/ AS Air purchased devices regarding usage, service needs and device performance. | Individuals (customers) Devices with consent. | Provide and support our products and services; respond to questions; help, secure, and troubleshoot; and marketing (where consent is obtained), | Service providers and user-directed entities |
| Geolocation data: Physical location, with express consent, including the precise, real-time location (i.e., geo-location) of your mobile device. This information will be used only for purposes of facilitating your use of our services/products. | Individuals (customers) Devices with consent. | Provide and support our products and services; respond to questions; help, secure, and troubleshoot. | Service providers and user-directed entities |
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
Sharing Personal Information
We may disclose your personal information to a third party, or our Service Providers, as defined under CCPA, for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In addition, we may disclose personal information to third parties for other notified purposes, as permitted by U.S. state data privacy laws.
We Do Not Sell Your Personal Information
You have the right to know whether your personal information is being sold. Your personal information is “sold” when it is provided with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA or other U.S. state data privacy laws. Please note a “sale” does not include when we disclose your personal information at your direction, or when otherwise permitted under law.
Trane Technologies does not sell your personal information.
Your Rights and Choices
The CCPA and other applicable law provides its residents with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you, to the extent required by applicable law:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, to the extent required by applicable law.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or your authorized agent, may make a verifiable consumer request related to your personal information.
A verifiable consumer request must
Making a verifiable consumer request does not require you to create an account with us.
Non-Discrimination
We will not discriminate against you for exercising any of your rights afforded under applicable law.
Disclosure of privacy rights requests
Below are metrics regarding Access, Delete and Do Not Sell My Personal Information requests submitted pursuant to the CCPA that Trane Technologies received, fulfilled (in whole or in part), and denied between January 1, 2022 and December 31, 2023. These requests were received from residents of California.
Requests to view and delete personal data:
| Year | Requests to know/access from CA consumers | Requests to delete | Do Not Sell Requests |
|---|---|---|---|
| 2020 | 0 | 0 | 0 |
| 2021 | 0 | 0 | 0 |
| 2022 | 1 | 0 | 0 |
| 2023 | 1 | 0 | 1 |
Three requests were denied in 2023 due to an inability to verify the request. All were Do Not Sell Requests.
This notice will be updated annually.
As noted above, we do not sell personal information, and do not use or disclose your sensitive data for purposes other than those listed above, without your consent, or as permitted or required under applicable laws.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage, or as otherwise provided by law.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, how to obtain this notice in a more accessible format, or wish to exercise your rights under applicable law, please do not hesitate to contact us using our Request Form or at 1-833-921-0919.
The practices described in this Policy are current Personal data protection policies as of September 2024. Trane Technologies reserves the right to modify or amend this Policy at any time consistent with the requirements of the relevant principles and applicable law.