Culligan International Company
Privacy Policy

Effective Date: July 9th, 2024

Introduction

Welcome to Culligan International Company’s (“Culligan,” “we,” or “us,” or “our”) Privacy Policy. This Privacy Policy describes how Culligan collects, uses, and discloses information about you, including the choices Culligan offers with respect to that information, and applies to your use of any website, app, or other service where we may collect your information (collectively, “Services”) For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.

If you are a California resident, please see our California Privacy Notice provided pursuant to the California Consumer Protection Act, as amended (the “CCPA”), below, for more information about how we may collect, use, and disclose your Personal Information.

This Privacy Notice should be read in conjunction with Culligan’s Terms and Conditions, and any other policy, agreement, or terms which may affect your relationship with us. Please read this Privacy Policy and Terms and Conditions carefully before using our Services. By using our Services or otherwise providing Personal Information to us, you agree to our Terms and Conditions and consent to our data collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, please discontinue use of the Services.

• Table of Contents

Click on the links to navigate to the sections:

• personal information we collect & why we collect it
• HOW WE COLLECT YOUR PERSONAL INFORMATION
• HOW WE DISCLOSE PERSONAL INFORMATION
• SOCIAL FEATURES ON OUR SERVICE
• ANALYTICS
• YOUR CHOICES ABOUT TRACKING & COMMUNICATIONS
• SECURITY & PASSWORDS
• AGE RESTRICTIONS
• DATA RETENTION
• CALIFORNIA PRIVACY NOTICE
• OTHER STATE PRIVACY RIGHTS
• INTERNATIONAL TRANSFERS
• CHANGES TO THE PRIVACY POLICY
• HOW TO CONTACT US

PERSONAL INFORMATION WE COLLECT AND WHY WE COLLECT IT

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. Personal Information does not include information that is publicly available, de-identified, or aggregated.

The chart below summarizes the types of Personal Information we may collect and why we may collect it. Culligan may use your Personal Information for any purposes not inconsistent with our statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and any purposes not prohibited by applicable law, including the purposes listed below.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect your Personal Information through various means, including when you directly provide it to us and automatically through your use of our Services. We may also collect Personal Information about you from our vendors and from other parties. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use features of our Services.

Personal Information that You Provide 

We may collect Personal Information about you directly from you when you:

• Register or maintain an account with us
• Enter search terms or provide other information through our Services
• Subscribe to receive our notifications
• Exchange communications with us by mail, email, phone, etc.
• Post comments to our online communities
• Obtain customer service or technical support
• Participate in promotional activities
• Post reviews or other information about our products or Services
• Connect with us via social media

Personal Information Collected Automatically

Culligan and/or our vendors may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device), the domain name of the website that allowed you to navigate to our Services, search engines used, the length of time spent on our Services, the pages you looked at on our Services, the address (or “URL”) of the websites you visited before and after visiting our Services, the frequency of your visits to our Services, and certain other available information. The methods we use to collect Usage Information include:

• Log Files. Log information is data about your use of our Services, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which may be collected and stored in log files.
• Cookies. Cookies are small files that a website transfers to your device through a web browser that enable the site’s or a vendor’s systems to recognize your device and to collect certain information. Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use session cookies, persistent cookies, and other tracking technologies (such as web beacons, discussed further below) to collect information about your interactions with our website, including information about your browsing behavior. Our website may also support third-party cookies. In general, our Service uses cookies and other tracking technologies as follows:
  • Where necessary to run our Service, for example by allowing you to log in.
  • To optimize the functionality of our Service, including by personalizing content for you, greeting you by name, and remembering your preferences (e.g., your choice of language or region).
  • For analytics purposes—for example, to help us understand how our website is used, to see what products most interest you, and determine how best to market our products to you. More information on website analytics is provided below.
  • For purposes of ad targeting and marketing to collect information about your browsing behavior on our Service to show you interest-based advertising when you visit other websites or use social media.
  • To determine if you open or act upon our email messages. Information on unsubscribing from our commercial email communications is provided below.
  • To obtain information about your interactions with our online advertisements, such as whether you clicked on an ad and the website where you may have seen the ad.
• Web Beacons (“Tracking Pixels”). Web beacons/tracking pixels are small graphic images (also known as “Internet tags,” “clear GIFs,” or “Pixel Tags”) embedded in web pages and email messages which may be used to count the number of visitors to the Service, to place cookies, to monitor how users navigate the Service, and to count content and advertising views.
• Embedded Scripts. An embedded script is website code that runs automatically when you load a webpage and is designed to collect information about your interactions with the webpage. It is active only while you are connected to the Service.
• Location–Identifying Technologies. Geo-filtering and other location-aware technologies may make assumptions about your location from your IP address for purposes such as verifying your location (e.g., for shipping), or restricting/providing content based on your location. Content on our Service may also be personalized based on location so we can provide you with more location-relevant content.
• Device and Activity Monitoring. Technologies that monitor and may record your interactions with our Services, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving our Services and customizing or optimizing your experience on our Services.
• Session Replay. In certain instances, we may collect information to help us analyze activity on our Services, our chat functionality, and mobile apps as applicable, through session replay technologies to help us understand and analyze how visitors use our Services, and to improve the Services. These technologies may collect the following types of information, among others: IP address; screen size; device type (unique device identifiers); browser information; geographic location; and preferred language.

Information We Collect from Other Sources

Culligan may also obtain information about you from other sources, including our vendors. We also may obtain your Personal Information from our parent, subsidiary, and sister companies. In some circumstances, we obtain Personal Information about you from other parties, including business partners, resellers, and data brokers, some of which may sell the information to us. To understand your rights and choices regarding Personal Information collected by other companies, please consult the privacy policies of the businesses that you interact with. We are not responsible for the privacy policies or privacy practices of other parties.

Information Collected from Generative AI Services

We may offer you the ability to interact with our interactive AI chatbot, the “Chatbot” or “Cullie.” By using the “Cullie” Chatbot, you are interacting with Culligan’s Generative AI platform and not a live person, and you are subject to Culligan’s general Terms and Conditions and this Privacy Policy. Do not provide confidential or proprietary information when using the Chatbot. Use of the Chatbot is for general information only; please understand that information, decisions, or advice provided by the Chatbot or any materials retrieved therefrom, including those to any third party, have not been reviewed for content or accuracy. Please contact us as provided below with questions regarding the Chatbot or if you require further information with the subject line “GAIS Help”. Note also that some technologies used on our website, including Cullie, allow us and our service providers to monitor and analyze how visitors use our website to better understand user behavior and improve our Services. When you interact with us online, information related to your behavior may be collected by us and our service providers.

HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose your Personal Information for any purposes not inconsistent with this Privacy Policy, our written statements at the point of collection, or applicable law. In general, we disclose Personal Information as follows:

• Within our group of companies including with our affiliates, subsidiaries, locations, brands, etc.
• With our agents, vendors, consultants, and other business providers in order for them to provide their services to us. For example, we may disclose your Personal Information to provide customer service, operate and improve our business and our Services, improve our products and customer service, help run our promotions (including coupons and rewards programs), process payments, perform auditing and quality control, communicate with you, and otherwise operate our business.
• With other parties for co-marketing purposes, to improve our products and Services, or to provide you with other products and Services that may interest you.
• With our advertising partners for the purposes of ad targeting, remarketing, and customized advertising content.
• As necessary, for the following purposes: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our Terms and Conditions; (d) to protect our operations and protect our rights, privacy, safety, or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
• With our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, exercising or defending against legal claims, etc.
• With other businesses in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

SOCIAL FEATURES ON OUR SERVICE

Certain functionalities on our Services permit interactions that you initiate between our Services and certain other services, such as social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and another’s service; “liking” or “sharing” Culligan’s content; and to otherwise connect our Services to another service (e.g., to pull or push information to or from our Services). If you use Social Features, information you post or provide access to may be publicly displayed by the social media service that you use. Similarly, if you post information on a social media service that references the Services (e.g., by using a hashtag associated with Culligan), your post may be used on or in connection with the Services or otherwise by Culligan and/or our affiliates. Also, both Culligan and the social media service may have access to certain information about you and your use of the Services and any social media service.

ANALYTICS

Our website uses analytics technology provided by our vendors to understand how users interact with the site, improve our web experience, and better market our products. These analytics services use cookies and other Tracking Technologies to collect information about how you use the Service. Personal Information collected by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these providers on servers in the U.S. (or elsewhere). See below for more information on your choices regarding analytics services.

YOUR CHOICES ABOUT TRACKING & COMMUNICATIONS

Cookies and Tracking Technologies

Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please review your browser’s Help menu for instructions, or visit www.allaboutcookies.org for more information. Please note that if you disable all cookies, some features of our Services may not function properly.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

Analytics and Advertising Technologies

You may choose not to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or the Network Advertising Initiative (“NAI”). To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit http://www.‌aboutads.info/choices/. To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that opting out only means that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).

We also use advertising services provided by Google Ad Services, such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content. For more information on how Google Analytics uses data collected through our services, visit http://www.google.com/policies/privacy/partners. To opt out of Google Analytics cookies, visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.

Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s “Limit Ad Tracking” or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID.

In addition, we may serve ads on other online services that are targeted to reach people on those services who are also identified in one of more of our databases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our databases and the databases of the other online services such as Facebook/Meta. We are not responsible for these services, including without limitation the security of the data they hold about you. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, to find out what options Facebook offers you to control such ads.

Culligan is not responsible for the effectiveness of any other parties’ opt-out options or the accuracy of their statements regarding their programs.

Email Communications

You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending a request to unsubscribe to us as provided below. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.

Text/SMS Messages

You may opt in to receiving text messages and alerts on the mobile phone number(s) you provide to us. For example, as part of the Culligan Filter Replacement Text Program. If you opt in, we may send you text messages (i) regarding your account; (ii) about our products and promotions (including advertisements, sales, and special offers); (iii) to investigate or prevent fraud; and (iv) to alert you in the event of an issue with any of your purchases. You do not have to opt in to text messages and alerts to use and enjoy our Service or products. If you opt in, standard text messaging charges may apply. You may choose to opt out from our text messages and alerts at any time.

SECURITY & PASSWORDS

We take commercially reasonable measures to protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and electronic storage are not completely secure, and Culligan cannot guarantee the security of your Personal Information. You are responsible for maintaining the secrecy of any credentials used to access your account with us. If you suspect any unauthorized activity associated with your account, please report that activity to us immediately.

AGE RESTRICTIONS

Our Services are intended for adults. If you are under eighteen (18) years of age, you are not permitted to use our Services and should not send any Personal Information to us. Culligan does not knowingly collect Personal Information as defined by the Children’s Online Privacy Protection Act (“COPPA”). If we learn that we collected Personal Information in a manner not permitted by COPPA, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with Personal Information, please contact us as provided below.

Data retention

We will store your Personal Information for no longer than is necessary for the performance of our obligations, to achieve the purposes for which the Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (“California Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”), and supplements our Privacy Policy, above. In the event of a conflict between any other Culligan policy, statement, or notice and this California Notice, this California Notice will prevail as to California consumers and their rights under and as defined by the CCPA.

This California Notice does not apply to job applicants or current and former California employees/contractors, or their designated beneficiaries, as applicable. If you are a California employee or current or former California employee/contractor, a separate California privacy notice will be provided to you in the course of your employment. If you are a California job applicant, please review our California Job Applicant Privacy Notice. If you are a California resident and you believe you interacted with us in a different capacity, or if you have any questions, please contact us as provided below.

1. Sales and Sharing of Personal Information

Although we do not sell Personal Information in exchange for money, some of the ways in which we disclose Personal Information for advertising may be considered “sales” or “sharing” under California law. Listed below are the categories of Personal Information we disclose for purposes of cross-context behavioral advertising or otherwise “sell,” or “share” as defined under California law. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.

Category of Personal Information:

• Identifiers
• Personal Information described in Cal. Civ. Code § 1798.80(e)
• Internet or other electronic network activity information
• Geolocation Data

Categories of Third Parties to which Information was Sold or Shared:

• Advertising companies
• Analytics companies
• Social networks

Purposes for Selling/Sharing:

• For marketing, advertising, certain types of analytics or similar purposes
• To show you relevant ads while you browse to internet or use social media

1. Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To submit a request, email us at CAPrivacyRequest@culligan.com or call us toll-free at 877-225-8757. Please note that if you submit a request to know, request to delete or request to correct, you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

1. Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

1. The categories of Personal Information we have collected about you, including:

1. The categories of sources from which the Personal Information was collected;
2. Our business or commercial purposes for collecting, using, selling, sharing, or disclosing Personal Information;

• The categories of recipients to which we disclose Personal Information;

1. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
2. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information

1. The specific pieces of Personal Information we have collected about you.

2. Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

3. Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

4. Right to Opt-Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt out, please email us at CAPrivacyRequest@culligan.com.

5. Right to Limit Use and Disclosure of Sensitive Personal Information. We do not collect, use, or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

6. Rights Related to the Use of Automated Decision-making Technology. Culligan will accommodate applicable rights under the CCPA related to automated decision-making technology, as applicable.

7. Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

1. California “Shine the Light”

We do not share Personal Information with third parties or affiliates for those other parties’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us as provided below.

OTHER STATE PRIVACY RIGHTS

This section supplements other parts of this Privacy Policy and provides additional information for residents certain States that provide privacy rights to their residents (each, a “Covered State”). If you a resident of a Covered State, you may have the right to submit certain requests relating to your Personal Information (or “Personal Data,” as applicable), as described below.

Additional Information about Certain Data Uses

Targeted Advertising. We may process your Personal Data for targeted advertising. To opt out, please email us at CAPrivacyRequest@culligan.com.

Sales of Personal Data. We may sell your Personal Data as “sell” is defined in some Covered States. To opt out, please email us at CAPrivacyRequest@culligan.com.

Making a Privacy Rights Request

If you are a resident of a Covered State, you may have the right to submit certain requests relating to your Personal Data as described below. To exercise any of these rights, please email us at CAPrivacyRequest@culligan.com or call us at 877-225-8757. Please note that we will need to authenticate your identity before your request can be processed. For authentication, you will be asked to log into your account or to provide two-to-three (2-3) pieces of Personal Data that we will match against our records.

Right to Access and Data Portability. You may have the right to confirm whether we are processing your Personal Data, to access your Personal Data, and to obtain a copy of Personal Data you provided to us in a portable format.

Right to Correct. You may have the right to request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and our purposes for processing it.

Right to Delete. You may have the right to request that we delete your Personal Data, subject to exceptions.

Right to Opt-Out. You may have the right to opt out of the following uses of your Personal Data: (a) targeted advertising; (b) the sale of Personal Data; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects.

Right to Appeal. Sometimes we are unable to process requests relating to your Personal Data, in which case, your request will be denied. If you are a resident of a Covered State whose privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request by emailing us at CAPrivacyRequest@culligan.com or call us at 877-225-8757.

Please note that if you make a privacy rights request, we will retain the Personal Data submitted in connection with your request for recordkeeping purposes.

INTERNATIONAL TRANSFERS

We are a United States company and we provide our Services subject to United States law. However, we may transfer information to our affiliates, vendors, and business partners in other countries around the world, subject to applicable laws, and as a result personal information may be transferred to, processed, and stored in the other countries. As such, courts, law enforcement, and authorities in other countries may, in certain circumstances, be entitled to access your Personal information. By using the Services or providing us with any information through the Services, you consent to this potential transfer, processing and storage of your information, and you acknowledge that other countries and jurisdictions may not provide the same privacy protections and their privacy laws may not be as comprehensive as those in the United States or in the country where you reside or are a citizen.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect technological advancements, legal and regulatory changes and good business practices or otherwise at our discretion subject to applicable laws. If we make any changes, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth at the top of the Privacy Policy.

Your continued use of the Services after we make changes to this Privacy Policy is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

CONTACT CULLIGAN

If you have any questions about this Privacy Policy, please contact Culligan via email at CAPrivacyRequest@culligan.com, or by calling us toll-free at 877-225-8757.

© 2024 Culligan International Company. All Rights Reserved.