PRIVACY

Old World Industries, LLC Legal Notices

PRIVACY POLICY

Last Modified: January 1, 2020

Introduction

Old World Industries, LLC (“Old World,” “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

The information you share with us allows us to provide the products and services you need and want while giving you the best experience.

Our Policy outlines:

  • How and why we collect your personal information;

  • How your personal information is used and protected;

  • When and with whom we share your personal information; and

  • What choices you can make about how we collect, use, and share your personal information.

This Policy applies to Old World Industries, LLC and any of its affiliate companies unless such company has adopted a separate privacy policy.

What Does this Privacy Policy Include?

This Policy covers how and why we collect, use, share, and protect your personal information:

  • On our websites and mobile services where this Policy is posted;

  • In email, text, and other electronic messages between you and our websites;

  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;

  • Through mobile and desktop applications you download from our websites, which provide non-browser-based interaction between you and our websites; and

  • Submitted by you to us through any communications (electronic or otherwise, including by mail or phone) regarding our products or services, such as rebate programs or warranty claim submissions.

Personal information is information that identifies you or reasonably can be linked to information that identifies you.

What Type of Information Do We Collect and How Do We Collect It?

We collect two types of information: (1) information we receive from you and (2) information we receive from others. Information we receive from you includes information you share with us, such as when you submit a “Contact Us” request through our websites. This also includes information you provide us through technology, such as through a cookie placed on your computer when you visit our websites. We also receive information from other sources to help us supplement our records, improve the personalization of our service to you, and detect fraud. Our goal is to limit the information we collect to the information needed to support our business.

We collect information to deliver the products and services you request and to help improve your overall experience with Old World and our various products and services. We collect information from you in a variety of ways when you interact with our websites and mobile services, and when you submit personal information to us when we interact with you during our promotions or at trade shows.

Information You Provide to Us

You share information with us in various ways at trade shows, promotional events or on our websites. For example, you share information when you:

  • Make an online purchase or other transaction with us or through third-party vendors acting on our behalf;

  • Request customer service or contact us (through our websites or otherwise);

  • Participate in our programs, such as product warranty registration;

  • Post a review or comment on our social media pages, or post a rating, review or other user-generated content on one of our websites or mobile services;

  • Participate in a rebate, contest, sweepstake, promotion, or survey;

  • Create an account on one of our websites or mobile services; or

  • Use features of our websites and mobile services that may ask you to grant us access to the camera or microphone on your computer or mobile device (such as voice search).

When you engage in these activities, you may share different types of personal information with us, such as your name, email address, physical or postal address, phone number, or date of birth. When you contact us by phone, your call may be monitored or recorded and you are notified of such at the time of your call.

You also may provide information to be published or displayed on public areas of our websites or social media pages or transmitted to other users of our websites or third parties. Your user contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our websites with whom you may choose to share your user contributions. Therefore, we cannot and do not guarantee that your user contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

You also provide us information in other ways through technology. Some of this information may be linked to you personally. This information helps our websites and mobile services work correctly and supports our customer marketing and analytics efforts – our work to understand our customers’ needs and provide information about our products and services. Below are a few examples:

  • Device Information: We collect technical information when you visit our websites or use our mobile applications or services. This includes information such as Internet Protocol (IP) address, the type of mobile device you use, your device operating system and browser type, a unique device identifier, the address of referring websites, the path you take through our websites, and other information about your session on our websites.

  • Browsing Information: We use our own and third-party technologies such as cookies, web beacons, and mobile device identifiers to collect information about the use of our websites and mobile services. We use these tools to provide an integrated and more personalized experience for you. For example: cookies enable us to provide you relevant information as you use or return to our sites; web beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our websites and other sites were effective. See “What are Your Choices? below for more information.

How Do We Use Your Information?

We use information that we collect about you or that you provide to us, including any personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use personal information to support our business functions, such as fraud prevention, marketing, and legal functions. Some examples include:

  • To present our websites and their contents to you;

  • To provide you with information, products, or services that you request from us;

  • To administer contests, sweepstakes, promotions, rebates, and surveys;

  • To provide customer services and alert you to product information, including recalls;

  • To help us personalize our service offerings, websites, mobile services, and advertising;

  • To send you information about our products, services, and promotions;

  • To respond to reviews, comments, or other feedback you provide us;

  • To protect the security and integrity of our websites, mobile services, and our business;

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

  • In any other way we may describe when you provide the information; and

  • For any other purpose with your consent.

How Do We Share Your Personal Information?

We will not sell or rent your personal information, except in the event all or a part of our business is merged, sold or reorganized. We may share your personal information in limited circumstances, such as to conduct our business, for other companies to offer you and administer your use of co-branded products or services, when legally required, or with your consent.

We will not share your personal information outside of our corporate family of companies (companies owned or controlled by Old World Industries Holdings, LLC), except in the following circumstances:

Service Providers

We share personal information about you with contractors, service providers, and other third parties that help with our business activities. Some examples include logistics providers, billing and refund vendors, payment card processors, IT providers that help us administer our systems and websites, temporary and agency workers that perform business functions for us, marketing vendors, and companies that help us improve our products and services. We require our service providers to keep your personal information secure. We do not allow our service providers to use or share your personal information for any purpose other than providing services on our behalf. Your personal information may be stored and processed by our service providers in the United States or other locations where the service providers maintain facilities.

Legal Requirements and Protection of Our Company and Others

We may share your personal information in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help protect the safety, property, or rights of Old World, our customers, our employees, or other persons. Examples include:

  • Protecting the health or safety of our customers;

  • Identifying and addressing fraud or financial risk;

  • Sharing your information with outside counsel for legal advice regarding your product or warranty claim or other issue;

  • Responding to a search warrant or other valid legal inquiry;

  • Responding to an investigative body in the case of a breach of an agreement or violation of law.

Business Transfers

In the event that all or a part of our business is merged, sold, or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), personal information about you could be shared with the successor business. We will use reasonable measures to help ensure that any successor treats your information in accordance with this Policy.

With Your Consent

In any circumstance other than those described above, we will ask for your affirmative consent before we share your personal information outside of our corporate family of companies, and we also will not sell or rent your personal information.

What are Your Choices?

We strive to provide you with choices regarding your personal information that we collect, use and share. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our websites may then be inaccessible or not function properly.

  • Marketing Communications. If you do not wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by clicking the “unsubscribe” button located at the bottom of all of our marketing emails, or by sending us an email stating your request at info@owi.com. If you contact us, please be sure to include your full name, the types of communications you would like to receive or not receive, and your related contact information. Please allow sufficient time for your marketing preferences to be processed. Please note that while we will unsubscribe you from future marketing communications, we still may need to contact you regarding your transaction, such as to provide you with warranty or recall information, or for information regarding your transaction. Since we do not accept opt-out requests from third parties, please communicate your request directly to us through one of the mechanisms mentioned above.

  • Interest-Based Advertising Preferences. We personalize your experience on our sites and mobile services by showing you advertisements that are tailored to your interests. We show you advertisements related to Old World products. We belong to ad networks that may use your browsing history across participating websites and mobile services to show you interest-based advertisements. You may also see ads for Old World’s products on participating websites and mobile services based on how you browse. We do not share personal information about you with companies that advertise on our websites without your consent. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (NAI) on NAI’s website: www.optout.networkadvertising.org.

  • Mobile Location Settings. Some of our mobile services may use your device’s location information. You can adjust the location settings of your mobile device at any time to control whether your device communicates this information. You will also need to adjust your device’s Bluetooth settings to completely disable the collection of Bluetooth location-related data. See your device’s instructions to learn more about these settings. In addition, we may offer you controls on our use of mobile location information.

  • Device Camera and Microphone. Some of the features on our websites and mobile services may require access to the camera or microphone on your computer or mobile device. You must give your permission before we access your device’s camera or microphone, and you can adjust the settings of your device at any time to control access to your camera or microphone.

How Do You Access and Update Your Personal Information?

You can access or update your personal information, including contact or account information, in the following ways:

  • If you have created an account on one of our websites, log into your account. Once you do, you will be able to enter and update your own contact information and payment information (if applicable).

  • Contact us through one of the ways listed in the “Who Can I Contact About the Privacy Policy?” section at the bottom of this Policy. Please include your current contact information, the information you are interested in accessing, and your requested changes. We will provide you the personal information requested if it is reasonably available, unless it infringes on the privacy of other individuals, and subject to reasonable limitations provided by law and internal procedures. Otherwise we will describe the types of information we typically collect. We will provide access and make the changes you request or will provide an explanation of what actions we will be able to take with regard to the request.

How Do We Secure Your Personal Information?

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our websites like message boards or on our social media pages. The information you share in public areas may be viewed by any user of our websites or social media platforms.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our websites.

How Does Old World Protect the Privacy of Children Online?

Old World’s general audience websites and mobile services are not directed to children under the age of 16 and do not knowingly collect personal information from children under the age of 16. If you are under 16, do not use or provide any information on our websites and do not provide us with any information about yourself, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us as directed under the “Who Can I Contact About the Privacy Policy” section below.

What Are Your California Privacy Rights?

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our Privacy Notice for California Residents, which may be found at www.owi.com/privacy .

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the contact listed below under the “Who Can I Contact About the Privacy Policy?” section below.

What Are Your GDPR Privacy Rights?

If you are a data subject of the European Union, as defined under the General Data Protection Regulation (Regulation (EU) 2016/679) of the European Parliament (“GDPR”), you may have additional rights regarding of use of your personal information and your access to and rights regarding your personal information. If you have any requests relating to such rights, please contact us with your request under the “Who Can I Contact About the Privacy Policy” section below, and we will address your concern.

Who Can I Contact About the Privacy Policy?

To ask questions or comments about this Policy and our privacy practices, please contact us at:

Old World Industries, LLC
3100 Sanders Road, Suite 500
Northbrook, Illinois 60062
Attn: Office of the Chief Legal Officer
Email: rstevens@owi.com
Phone: (847) 559-2224 or (847) 559-2007

How Will I Know if this Policy Changes?

The Policy may change from time to time. Please check our Privacy Policy periodically for changes. We will provide additional notice by emailing you at the email address that you provided of any material updates. We will post the date our Policy was last updated at the top of the Privacy Policy.





PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Last Modified: January 1, 2020

Introduction

This Privacy Notice for California Residents supplements the information contained in Old World Industries’ general Privacy Policy and its Employee Privacy Policy and applies solely to those who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice applies to Old World Industries, LLC and any of its affiliate companies.

The CCPA temporarily provides an exemption for the application of certain provisions regarding employment-related personal information collected from California-based employees, job applicants, contractors or similar individuals (“Employee Exemption”) and personal information reflecting a written or verbal business-to-business communication (“B2B personal information”). Accordingly, this Notice only applies to the extent of the currently applicable provisions of the CCPA and your rights may be different if you fall under either of these exemptions.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:





Category


Examples


Collected


A. Identifiers.


A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.


YES


B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).


A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.


YES


C. Protected classification characteristics under California or federal law.


Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).


YES*


D. Commercial information.


Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.


YES


E. Biometric information.


Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.


YES*


F. Internet or other similar network activity.


Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.


YES


G. Geolocation data.


Physical location or movements.


YES


H. Sensory data.


Audio, electronic, visual, thermal, olfactory, or similar information.


YES


I. Professional or employment-related information.


Current or past job history or performance evaluations.


YES*


J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).


Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.


YES*


K. Inferences drawn from other personal information.


Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


NO




*These categories of information are only collected (when applicable) from our employees, job applicants, or contractors. These categories of information are not collected from consumers.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, when you complete a rebate form, submit a product claim, or submit a “contact us” request on our website.

  • Indirectly from you. For example, from observing your actions on our websites.

For more information, please see Old World’s Privacy Policy in the section entitled, “What Type of Information Do We Collect and How Do We Collect It?”

Use of Personal Information

For information on how we use your personal information, please see Old World’s Privacy Policy in the section entitled, “How Do We Use Your Information?”

Sharing Personal Information

We will not sell or rent your personal information, except in the event all or a part of our business is merged, sold or reorganized. Old World has not sold or rented any personal information in the past 12 months.

For more information on how we share your personal information, please see Old World’s Privacy Policy in the section entitled, “How Do We Share Your Personal Information?”

The following are categories of third parties with whom we may share your personal information for a business purpose:

  • Service providers;

  • Data aggregators;

  • Advertisers;

  • Affiliates;

  • Partners;

  • Parent of subsidiary organizations;

  • Social media companies;

  • Internet cookie data recipients, like Google Analytics.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers;

  • Category B: California Customer Records personal information categories;

  • *Category C: Protected classification characteristics under California or federal law;

  • Category D: Commercial information;

  • *Category E: Biometric Information;

  • Category F: Internet or other similar network activity;

  • +Category G: Geolocation data;

  • +Category H: Sensory data;

  • *Category I: Professional or employment-related information;

  • *Category J: Non-public education information;

*These categories of personal information are only collected for our employees, job applicants and contractors, if applicable, and are only shared with service providers, data aggregators, affiliates and parent and subsidiary organizations.

+These categories of personal information are only disclosed (if applicable) to provide further services to you, such as a mobile application that allows you to find a location nearest to you, or a voice-activated option on an application.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Please note that for employees and B2B personal information, the following rights are currently exempt from the CCPA and may not apply to you. You are welcome to contact us and we will use commercially reasonable efforts to address your concerns, but we cannot assure you of strict compliance with the rights and choices articulated below.

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 (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.

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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our services provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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 phone or email directed to the following:

Old World Industries, LLC
3100 Sanders Road, Suite 500
Northbrook, Illinois 60062
Attn: Office of the Chief Legal Officer
Email: rstevens@owi.com
Phone: (847) 559-2224 or (847) 559-2007

If you use any of our services that require you to form an account with us, you can access your information in the profile section of the website or mobile application. You may also request to delete your personal information if there is a “contact us” feature located with your specific web portal or mobile application.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

Old World is not in the business of selling or renting personal information, does not intend to sell or rent personal information, and has not in the past 12 months sold or rented any of your personal information. Accordingly, we do not have a mechanism to opt out as we do not sell personal information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

How Will I Know if this Notice Changes?

The Notice may change from time to time. Please check our Notice periodically for changes. We will provide additional notice by emailing you at the email address that you provided of any material updates. We will post the date our Notice was last updated at the top of the Notice.