Fluidmaster Privacy Policy Effective July 1, 2020

The Fluidmaster Privacy Policy summarizes the various ways that Fluidmaster, Inc. (“Fluidmaster,” “we” or “our”) uses the information you provide while using Fluidmaster.com, what information we collect and why we collect it, how we use it, how you can control the information we process and how we protect your personal information.

By voluntarily accessing and using any part of the Fluidmaster website (the “Website”) and/or contacting us through customer service, you will be deemed to have consented to the collection and use of your personal data in accordance with the terms of this Privacy Policy. If you do not consent to the processing of your personal data in accordance with the terms of this Privacy Policy please do not access or use the Website.  By sharing your personal information with us, and by continuing to use our Website, you confirm that you have read and understood the terms of this Privacy Policy.  In this Privacy Policy, when we refer to “Fluidmaster”, “we”, “our”, or “us”, we mean the Fluidmaster group of company or companies which provide the Fluidmaster Website or Fluidmaster products (including Fluidmaster Inc., Opella Limited, Fluidmaster Netherlands, B.V., and Fluidmaster Predelava Plastike d.o.o.).

In this Privacy Policy, we tell you about Fluidmaster’s personal data processing and provide information on how we use personal data about you in specific situations such as for marketing, when you apply for a job at Fluidmaster, when you enter a contract with Fluidmaster and when you visit the Website or functions linked to the Website.

Fluidmaster complies with applicable United States (‘U.S.’) state and federal laws and applicable laws outside of the U.S. where required, including within the European Union.  If you are a California resident or a data subject in the European Union or Switzerland, please see the California and European Union and Switzerland sections, respectively. If you have any questions or wish to exercise Your rights and choices, please contact us as set out in the Contact section below

This Privacy Policy contains the following information:

  • Why do we process your personal data?
  • What kind of information do we collect about you?
  • How do we use information about you?
  • Do we share information about you with others?
  • Is there a data transfer of your personal information?
  • How long do we store information about you?
  • What are cookies and how they are used on this website?
  • How do we protect information about you?
  • What are your rights related to personal data processing?
  • What to understand before clicking links to third party websites?
  • Can this Privacy Policy be changed?

We may collect and otherwise process the following information about you (including personal information):

  • Information you share with us – When you contact us, interact with us on the Website, contact us through customer service, and fill out forms on the Website. In such cases, you may share with us: your name, address, e-mail address, contact number and payment and credit card information. In some circumstances, we will need that information to be able to provide you with a product or service that you have asked for; for example, we need your payment information when you buy a product, and your address to deliver it to you. We may also use your information to respond to customer service requests and support needs and to improve our services or our Website.
  • Information we collect from your interactions on the Website – We may automatically collect details of your visits to the Website (including, but not limited to, IP address, traffic data, location data, weblogs and other communication data) and the resources that you access. The information we collect may also include records of correspondence and information you provide to us if you contact us via this Website or other ways of communication, such as postal addresses. We also collect details of transactions you carry out through our Website and of the fulfilment of your orders. We may collect information about your computer, including where available your IP address, operating system and browser type.
  • Information from other third parties – We also collect and handle information about how you engage with our promotional campaigns, marketing and advertising online, outside of our own websites. We collect information, including aggregated demographic data that provide insights into the households that purchase our products, from third party data providers who help us to give you a more relevant owner experience by enabling us to provide offers at the right time, and to give you more relevant services and advice.

How to contact us?

You can find more detailed information about how Fluidmaster processes personal data on the following topics by clicking on the link:

Marketing Privacy Notice-2018

Why do we process your personal data?

We may collect personal data on you for a variety of reasons. For more information on a specific type of data processing, please look to the topic specific privacy notices listed above, such as our Marketing Privacy Notice.

What all personal data processing by Fluidmaster has in common is that the data processing is necessary in order for Fluidmaster to carry out its rights or obligations related to you. For example, if you are a customer, by collecting your personal data we may aim to provide you with the services or products you have requested; develop, enhance and personalize your customer experience; maintain and develop our customer relationship with you; and communicate with you more efficiently.

What kind of information do we collect about you?

We primarily collect personal data directly from you. You may provide us data for example by contacting us, or providing feedback, registering as a user of our services, applying for a job, subscribing to our newsletters or other material, commenting on or discussing any content on the Website, or downloading or uploading material.

The types of personal data we collect about you typically include information such as:

  • Contact Information – your identification and contact details, such as your name, company, email address, address and telephone number;
  • Commercial/Transactions – information on the customer relationship, such as communication preferences, your product interests and the use of Fluidmaster products and services, and proof of purchase to process warranty claims
  • Identifiers – your login information such as the user name and password in our Fluidmaster Login Account or in Preference Center; and
  • Internet/Electronic Network Activity – technical information, such as your IP address and the equipment you use to access our Website.
  • Education and Employment – disclosed in the process of applying for a job.

It is always up to you whether you want to give personal data to us. If you choose not to do so, please note that we might not be able to carry out an action you have requested. We may not be able to, for example, register you as a user, consider your job application, or provide you with our products or services.

When necessary, we may also use cookies and related technologies provided to us by third parties, and create new information by analyzing the data we already have on you. Your web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about you. you may choose to set your web browser to refuse cookies or to alert you when cookies are being set, although some parts of the Website may not function properly More information about the use of cookies is provided below in the section “What are cookies and how are they used on this website?”

How do we use information about you?

How we use information about you depends on why the information was originally collected. To give you an idea of how we process personal data, we have included some examples below. For more detailed information, please see our topic specific privacy notices.

In general, we tend to use your personal data for the following purposes:

  • to sell products and services to you;
  • to deliver goods or services to you;
  • to provide customer support for sold products or services;
  • to conduct surveys;
  • to secure and optimize the website experience;
  • to provide marketing communication;
  • to secure and control the access to Fluidmaster premises;
  • to carry out the recruitment process; or
  • to otherwise enable us to fulfill our legal and contractual obligations.

Data protection and privacy laws in some countries require us to have what’s called a “legal basis” or “lawful ground” for handling personal information. Broadly, that means that we have to have a legal justification for handling your personal information. For the most part, we need to handle your personal information to be able to provide you with the products or services that you have asked for; and for our products and Websites to be able to work properly and to do all the things that you expect them to.

Sometimes, our use of your personal information is not strictly necessary for us to be able to provide you with our products and services, or for them to work properly. In those circumstances, we have what’s called a “business purpose” or “legitimate interest” in handling your personal information; our “business purpose” or “legitimate interest” may be to:

  • detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
  • keep our websites, apps, products and IT systems secure through debugging to identify and repair errors that impair existing intended functionality;
  • ensure that our own processes, procedures and systems are as efficient as possible; analyze and enhance the information that we collect;
  • maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments;
  • providing advertising services, marketing services and/or analytic services to determine the effectiveness of our promotional campaigns and advertising; and customize and improve the way that you shop and engage with us in future.

There will be certain personal information that you share with us which we specify as being optional (for example, when you update your account information). We will explain how we use that information and if you choose to provide it to us, you are agreeing to our use of your information in that way. You can ask us to delete that information at any time by contacting Fluidmaster customer service or by contacting us at dpr@fluidmaster.com

Finally, in some, relatively limited circumstances we will need to handle your personal information in a certain way to be able to comply with our legal obligations; for example, if we are requested to disclose your personal information to regulatory bodies or law enforcement authorities.

Ultimately, the reason we handle your personal information in the way we do is so that we can directly or indirectly, improve our products, services and your overall experience with Fluidmaster. Whatever our justification for handling your personal information (whether it is necessary for us to provide you with a certain product, or it is in our “business purpose” or “legitimate interests”), we make sure that we take steps to honor our commitment to protect your privacy.

Do we share information about you with others?

We use third parties, such as service providers, to collect, store and process personal data on our behalf and to provide you with products and services.  For example we share your name and address with freight carriers to ship product in response to warranty claims. We also share aggregated, non-personally identifiable information with Google Analytics to analyze our website traffic and Facebook for advertising campaigns.  Such service providers are only allowed to process your personal data to the extent necessary for them to provide the service we have requested from them. As a main rule, they are not allowed to use your personal data for the benefit of their own business.

In order to protect your privacy, we require that all our service providers keep the personal data we provide them confidential and adequately secure. They are also required to abide by data processing agreements and applicable data protection legislation.

Additionally, Fluidmaster may disclose and transfer your personal data within the Fluidmaster group of companies.

As Fluidmaster is a global group of companies with affiliates and service providers within California, the European Union and other countries or regions, your personal data may be transferred outside the European Union. The countries to which your data is transferred may not provide the same level of data protection as your home country. Despite this, when transferring personal data to foreign countries, we will always look after its safety by ensuring that there is a legal basis for the transfer and that applicable laws governing data transfers are followed.

Is there a data transfer of your personal information?

Fluidmaster will collect personal information from you in the country in which you live. We, and those third parties that we share your personal information with, then host, store and otherwise handle that information in the UK, in the countries within the European Economic Area (EEA) or in any country outside of the EEA, where we do business.

We will make sure that any transfers of your personal information from one country to another comply with those data protection and privacy laws which apply to us. European data protection laws, in particular, include specific rules on transferring personal information outside the EEA.

When transferring personal information outside the EEA, we will include standard data protection clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties (these Clauses are approved under Article 46.2 of the GDPR); or ensure that the country in which your personal information will be handled has been deemed “adequate” by the European Commission under the GDPR Article 45.

In any case, our transfer, storage and handling of your personal information will continue to be governed by this Privacy Policy. If you would like further information about the transfers of personal data, please contact us at dpr@fluidmaster.com.

How long do we store information about you?

We store personal data only as long as is necessary to fulfil our rights and obligations related to the data. However, as these rights and obligations vary from one processing situation to another, we provide more information on such storage times in the topic specific privacy notices.

Once personal data is no longer necessary, we delete it or anonymize it as soon as possible.

What are cookies and how are they used on this website?

We use cookies on the Website to improve the Website’s functionality and to obtain information regarding visits to the Website.

Cookies are small text files stored on your computer’s hard drive which allow your computer to be recognized by the Website. We may use either cookies which save a file on your computer permanently (permanent cookies) or cookies which disappear when your browser is closed (session cookies).

Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our site.  Visitors to our Website use different web browsers and different computes.  To make your visits as easy as possible with the technology you use, we automatically keep track of the browser (e.g., Internet Explorer, Safari) and operating system (e.g., Windows, Mac) used by a visitor, and the domain name of the visitor’s internet service provider (IP address).  This information generally includes data which does not allow individual identification of information relating to a specific user. If, however, we hold personal data about you, information collected by the use of cookies may be combined with such data.

Information gathered by cookies is used for statistical and analytical purposes such as maintaining statistics regarding the use of the Website, to conduct surveys in order to improve the Website and/or Fluidmaster’s other products and services, to determine which parts of the Website are most popular, to provide information to third parties so that appropriate advertising may be directed to you, and to optimize the use of the Website. Cookies are also used to recognize you when you return to the Website in order to, for example, provide you with information related to your own interests.

We use a range of third party tools on this Website to enable features such as social media sharing and survey forms. In some cases, these third-party tools will place a cookie on your computer and use tracking technology for the purpose of personalizing your experience or targeting advertising. These third-party cookies may include, among others, Google Analytics. Please refer to the privacy notices of each cookie provider for more information on their privacy practices.

The cookies used by us are based on the International Chamber of Commerce guide for cookie categories.  A list of all the cookies used on this website by category is set out below.  Please refer to Fluidmaster’s Cookies Policy for additional detail.

  • Strictly Necessary Cookies are essential for you to navigate our Website and use its features, such as secure areas, shopping baskets and online billing. These cookies do not gather any information about you that could be used for marketing or remembering where you’ve been on the internet.  We use Strictly Necessary Cookies to identify you as being logged in to the Website and to authenticate you as well as for security purposes.
  • Performance Cookies collect information about how you use our Website, such as which pages you visit and if you experience any errors. These cookies do not collect any information that could identify you.  All of the information collected is anonymous and is only used to help us improve how our Website works, understand what interests visitors to our Website, and measure how effective our advertising is.
  • Functionality Cookies are used to provide services or to remember settings to improve your visit to our Website. Functionality cookies will not be used to target you with advertising on other websites.
  • Targeting Cookies are linked to services provided by third parties, such as “Like” buttons and “Share” buttons. The third party provides these services in return for recognizing that you have visited our Website.  We use Targeting Cookies to link to social networks like Facebook and Instagram who may subsequently use information about your visit to target advertising to you on other websites.  We also use Targeting Cookies to provide advertising agencies with information on your visit so that they can present you with advertising that may be of interest to you.

Opting out of Cookies

You may choose to refuse cookies and delete cookies by using the settings and features of your browser. As your browser may be set to accept cookies by default, we encourage you to review your browser settings in case you are concerned about the use of cookies on the Website. Please note, however, that some parts of the Website may require cookies to function. Should you choose to set your browser to refuse cookies, you may be unable to access such parts of the Website.  See our Cookie Policy for more details.

How do we protect information about you?

Fluidmaster uses robust measures to protect the personal data it holds. These measures include guidelines, procedures and protections meant to limit third party access to the data, but also measures taken in order to limit our own personnel’s and service providers’ access to data they do not need in their tasks. In case you wish to learn more about our security measures, you can contact our data privacy representative.

Fluidmaster will make every reasonable effort to secure its Website and protection measures but does not represent, warrant, or covenant anything related to sage, complete, or hack-proof transmissions in transit or at rest. You assume the risk of any unauthorized disclosure or intentional intrusion, or of any delay, failure, interruption, or corruption of data or other information transmitted or stored at rest in connection with the use of the Website.

What are your rights related to personal data processing?

As a registered Fluidmaster customer, you may access and amend your contact details and other profile information at any time through the Fluidmaster Login Account, Fluidmaster Preference Center or other Fluidmaster user account you have registered.

You have the right to access the personal data we have collected on you and request that we erase or rectify any erroneous, unnecessary, incomplete or obsolete personal data. In addition, you have the right to withdraw your consent to or otherwise opt-out of the collection of location data and/or direct marketing.

You may use the rights described above and/or express any concern you might have about our use of your personal data by contacting our data privacy representative via the contact details provided below in the section titled “How to contact us?”

We will do our best to resolve any issue you might have related to our processing of your data. However, if you are not satisfied with our answers or actions, you may always turn to your national data protection authority.

California

The following disclosures apply only to individuals who reside in California. The California Consumer Privacy Act (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.

California Notice of Collection. We collect information corresponding to the following categories of information identified in the CCPA.

  • Identifiers, including name, address, email address, account name, date of birth, Social Security Number, IP address and account identification details assigned to your account.
  • Customer records, phone number, billing address, credit or debit card information, employment or education information.
  • Analytics and Advertising, including purchases and engagement with the Website.
  • Internet activity, including history of visiting and interacting with Our Website, browser type, browser language and other information collected automatically.
  • Geolocation data.
  • Inferences, including information about interests and preferences.

We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities, We will comply with applicable law as to such activity.

We disclose the following categories of information for commercial purposes:

  • Commercial Information;
  • Customer Records;
  • Demographic Data;
  • Location Data;
  • Identifiers;
  • Inferences; and
  • Internet activity.

We use and partner with different types of entities to assist with daily operations and manage the Website.

Right to Know and Delete. If You are a California resident, You have the right to know certain information about Our data practices in the 12 months preceding any such request. In particular, You have the right to request the following from Us:

  • The categories of Personal Information We have collected about you;
  • The categories of sources from which the Personal Information was collected;
  • The categories of Personal Information about You that We disclosed for a business purpose or sold;
  • The categories of third parties to whom the Personal Information was disclosed for a business person or sold;
  • The business or commercial purpose for collecting or selling the Personal Information; and
  • The specific pieces of Personal Information We have collected about you.

You also have the right to have the Personal Information that we have collected from you deleted. This is, however, not an absolute right and we may have legal grounds for keeping such data.

Exercising Your Rights. To exercise any of these rights, please call us at our toll-free number at 833-987-0879, email us at privacy@fluidmaster.com or complete our privacy request form.  Your request should specify which right you are seeking to exercise and the scope of the request.  We may require specific information from you to help us verify your identity and process your request. After verifying your identity, we will process your request within 45 days.  If We are unable to verify your identity, We may deny your requests to know or delete.

Authorized Agent. You can designate an authorized third party to submit requests on your behalf. However, We will require written proof of the agent’s permission to do so and verify your identity directly,

Right to Non-Discrimination. You have the right to not be discriminated against by Us as a result of your exercising any of your rights.

European Union and Switzerland

Data Sub-processor. If You are a Fluidmaster customer or partner, We and/or Our third party agents act as Your data sub-processors. We primarily process and store your data, including personal information, on servers located and operated within the U.S. If you reside or are located outside of the U.S., We may send to and store your personal information in the U.S. in order to provide and operate the business and our Website. If Your personal information (as defined in the EU General Data Protection Regulation (“GDPR”) as “personal data”) that is being processed by Fluidmaster is subject to GDPR, We undertake to ensure an adequate level of protection of the personal data transferred outside the European Economic Area, either by us, Our affiliates, and/or third party agents, in accordance with applicable legislation, in particular via the signature of the standard contractual clauses approved by the European Commission.

If You wish to exercise any of these privacy rights under GDPR, or if You need further information regarding those privacy rights, please contact us at dpr@fluidmaster.com.

Data Controller. In limited circumstances, where Fluidmaster processes your personal information as a data controller, you are entitled to certain privacy rights under certain circumstances:

  • Right of access;
  • Right to rectification;
  • Right to erasure (Right to be forgotten);
  • Right of restriction of processing;
  • Right to data portability;
  • Right to object;
  • Automated individual decision-making, including profiling.

What to understand before clicking links to third party websites?

The Website may contain links to third party websites. Any information you provide on third party sites or services is provided directly to the operators of such services and is subject to those operator’s policies, if any, governing privacy and security, even if accessed through our Website.  Please note that Fluidmaster is not responsible for the privacy practices or contents of any such third-party website. Since this Privacy Policy only applies to this Website, you should read the privacy notices of websites when you open them.

Can this Privacy Policy be changed?

It is our policy to post any changes we make to our Privacy Notice on this page.  We may update this Privacy Policy at any time without expressly notifying you of such changes. The up-to-date version of the Privacy Policy can always be found on this Website.

We recommend that you revisit this Privacy Notice from time to time in order to review any possible changes.  It is Your responsibility to review this Privacy Policy periodically and be aware of modifications.

How to contact us?

If you have any questions or requests regarding this Privacy Notice or the personal data we at Fluidmaster hold about you, please contact our Privacy Office:

For General Data Protection Regulation (GDPR) inquiries email us at dpr@fluidmaster.com.

You can revoke your individual consent at any time by sending us an email to dpr@fluidmaster.com or via mail.

For California Consumer Privacy Act (CCPA) inquiries call us at our toll-free number at 833-987-0879, email us at privacy@fluidmaster.com, or complete our privacy request form.