Culligan International Company

Privacy Policy

Effective Date: June 5th, 2025

INTRODUCTION

Welcome to Culligan International Company’s (“Culligan,” “we,” “us,” or “our”) Privacy Policy. This Privacy Policy describes how Culligan collects, uses, and discloses information about individuals who use our websites, mobile apps, or other services where we may collect Personal Information (collectively, “Services”). For certain Services, we may provide additional notices about our privacy practices. When applicable, please read those additional privacy disclosures to understand how they apply to you.

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 the Terms and Conditions carefully before using our Services. By using our Services or otherwise providing Personal Information to us, you consent to the collection, use, communication, disclosure, and processing of your Personal Information as described in this Privacy Policy. If you do not agree, please discontinue use of the Services.

TABLE OF CONTENTS

• PERSONAL INFORMATION WE COLLECT
• WHY WE COLLECT PERSONAL INFORMATION
• HOW WE COLLECT PERSONAL INFORMATION
• COOKIES AND OTHER ONLINE TRACKING TECHNOLOGIES
• HOW WE DISCLOSE PERSONAL INFORMATION
• SOCIAL FEATURES ON OUR SERVICE
• YOUR CHOICES ABOUT TRACKING AND COMMUNICATIONS
• Cookies and Tracking Technologies
• Analytics and Advertising Technologies
• Email Communications
• HOW WE SAFEGUARD PERSONAL INFORMATION
• AGE RESTRICTIONS
• DATA RETENTION
• INTERNATIONAL TRANSFERS
• CHANGES TO THIS PRIVACY POLICY
• CONTACT CULLIGAN
• ADDITIONAL U.S. STATE PRIVACY NOTICE
• Targeted Advertising and Sales
• Do Not Track Signals
• Text/SMS Messages
• Making a Privacy Rights Request
• Additional Disclosures for California Residents
• ADDITIONAL CANADA PRIVACY NOTICE
• Additional Personal Information We Collect
• How We Disclose Personal Information Within Our Organization
• How We Safeguard Personal Information
• Marketing and Advertising
• Privacy Rights
• Cross-Border Transfer of Personal Information
• Right To Withdraw Your Consent
• Material Changes to this Privacy Policy

PERSONAL INFORMATION WE COLLECT

“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. Personal Information includes “Personal Data” as defined in applicable privacy laws.

We may collect the following Personal Information about you:

Contact Information and Identifiers, including name, account name, username, unique personal identifier, online identifier, IP address, email address, physical address, and phone number.

Commercial Information, including purchase, payment, billing, and other financial information; records of products or services purchased, obtained, or considered; and other purchasing or consuming histories or tendencies.

Demographic Information, including age and birth date.

Internet or Other Electronic Network Activity Information, including internet or other similar activity, browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, browser type, application logs, device model and operating system, referring domains, timestamps (time a page was accessed as well as time spent on each web page), user clicks, visit duration, as specific pages visited by the user of the Services, and social media account information. For more information about how we collect information through cookies and other tracking technologies, please see the “Cookies and Other Tracking Technologies” section below. For more information about how we process information through social media, please see the “Social Features on Our Service” section below.

Location Data, including physical location based on information you provide directly or inferred from your IP address.

Audiovisual Information, including audio recordings of customer care calls, video, or similar information, as permitted by applicable law.

Communications with Us, including the contents of your communications with us via phone, email, text message, chat, or other means (such as survey responses, product reviews, and comments on our blog and social media pages).

Marketing and Communications Information, including the processing of your preferences in receiving marketing materials from us and your communication preferences.

We may collect information about the performance of Culligan products and may combine this with Personal Information we process about you. We may also collect aggregate and anonymized information, such as statistical data, regarding the use and performance of our Services, for lawful purposes. For example, we may aggregate information to calculate the percentage of users accessing specific Service features or using the Services in a certain way. The aggregated and anonymized information we use does not allow any individual to be identified.

The Personal Information we collect about you may not include all of the examples listed above, depending on your interactions with us.

WHY WE COLLECT PERSONAL INFORMATION

We 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.

We collect Personal Information for the follow purposes:

Providing Our Products and Services, including processing orders, transactions, and payments; allowing you to participate in the features we offer; maintaining your accounts; providing you with appropriate products and recommendations; and helping you find relevant products and services.

Identifying You, including confirming your identity when signing up to use the Services, verifying your identity to process a transaction, and recognizing you when you use our Services.

Communicating with You, including contacting you about our products and Services, your orders, and updates to our terms and policies; obtaining your feedback; confirming your preferences; and tailoring our communications to you.

Providing Customer Support Services, including the provision of customer support services over the phone, by email, or through online chats to assist with inquiries, technical issues, or other matters related to the Services.

Conducting Analytics and Improving Our Products and Services, including understanding and improving our Services and products; providing you with a better Service experience; and performing research and analytics.

Serving Marketing and Advertising, including sending you relevant marketing materials and advertisements; showing you relevant ads while you browse the internet or use social media; sending you relevant coupons, discounts, or promotions; and allowing you to participate in our promotions, sweepstakes, contests, and loyalty programs.

Operating our Business, including performing audits, research, and analysis; maintaining our Services; administering our relationships with our customers, dealers, suppliers, and other vendors; fulling purposes that we describe to you at the time we collect your information; in connection with mergers, acquisitions, divestitures, or similar corporate transactions; and otherwise managing our business.

Securing our Services and Detecting Fraud, including detecting, identifying, investigating, responding to, and preventing fraud and illegal or malicious activities against you and/or us; protecting our Services; authenticating users of the Service; and monitoring of unauthorized accesses, mitigating risks, ensuring the integrity and confidentiality of your Personal Information, and generally providing a secure Services.

Managing Legal and Compliance, including preparing for and participating in litigation; enforcing our policies and terms; protecting our rights; fulfilling our legal obligations; managing risk, investigations, and reporting requirements; and complying with other legal and regulatory obligations.

HOW WE COLLECT PERSONAL INFORMATION

We may collect your Personal Information through various means, including:

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, including by mail, email, phone, or chat.

Post comments to our website or social media pages.

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.

Automatically Through Your Use Of Our Services through cookies and other online tracking technologies, as described in the “Cookies and Other Online Tracking Technologies” section below.

From Our Authorized Dealerships And Franchises, including when you purchase our products, sign up for our Services, and register for home installation through your local dealership or franchise. Dealerships and franchises provide us information about your Culligan system and your Personal Information so we can provide and improve our products and Services and otherwise operate our business.

From Our Parent, Subsidiary, and Sister Companies, including to provide our Services and operate our business.

From Our Vendors that help us operate our business and collect Personal Information on our behalf, including software and website vendors.

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.

We may offer you the ability to interact with our interactive artificial intelligence (“AI”) chatbots (the “Chatbot”). By using the 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 “Generative AI Help”. Some technologies used on our Services allow us and our service providers to monitor and analyze how visitors use our Services 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.

COOKIES AND OTHER ONLINE TRACKING TECHNOLOGIES

Culligan and/or our vendors may automatically obtain certain information about you through cookies and other online tracking technologies (collectively, “Cookies”) when you access or use the Services (“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 other Internet or Other Electronic Network Activity Information.

In general, our Services use Cookies as follows:

Where necessary to run our Services, including allowing you to log in.

To optimize the functionality of our Services, 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, including helping us understand how our Services are used, seeing what products are the most interesting to visitors, enhancing our web experience, and improving our product marketing.

For purposes of ad targeting and marketing, including collecting information about your browsing behavior on our Services and showing 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, including understanding when an ad was clicked and the website where the ad was seen.

For device and activity monitoring purposes, including confirming identity, maintaining security, preventing fraud, troubleshooting, tracking and/or improving our Services, and customizing or optimizing experiences on our Services.

We may generally identify 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. Our Services may also be personalized based on your general location so we can provide you with more location-relevant content.

In certain circumstances, 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.

See below for more information on your choices regarding Cookies.

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:

With Our Related Entities, including with our affiliates, subsidiaries, locations, brands, and other related entities so that those entities may assist us in providing the Services to you, align business strategies, and develop new products and services.

With Our Agents, Dealers, and Franchise Owners, in order for them to provide their services to us. For example, we may disclose your Personal Information to provide customer service, operate our business and Services, provide our products and Services to you, install our products, including at your location, manage our Services, process payments, perform auditing and quality control, communicate with you, and otherwise operate our business.

With Our Vendors, Consultants, Service Providers, and Other Business Providers that help us provide the Services and otherwise run our business, including:

Website hosting providers, who process information collected through the Services, in order to provide and improve the Services and manage website security.

Data storage providers, who may process all information we collect and store in the course of providing, troubleshooting, and managing our data storage solutions.

Analytics and reporting service providers, who may process user information such as registration, or other anonymized or aggregated data in order to provide analytical insights to help us understand and develop our business.

Customer support providers, who process your marketing and communications data in order to help provide customer support to you.

Marketing providers and business partners for co-marketing purposes, to improve our products and Services, for marketing and communication purposes, to facilitate our marketing campaigns, or to provide you with other products and Services that may interest you.

Advertising partners for the purposes of ad targeting, remarketing, and other advertising; providing you with promotional material that may be of interest to you; and customized advertising.

Insurers and professional advisers for the purposes of managing risks, obtaining professional advice, and exercising or defending against legal claims.

For Legal and Compliance Purposes, including: to comply with any legal process; to respond to requests from public and government authorities; to enforce our Terms and Conditions and policies; to safeguard our operations; to enforce and protect our rights, privacy, safety, or property, and/or that of you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.

With Potential Acquirers 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).

To the extent we provide these parties access to your Personal Information obtained through our mobile apps, we require that they provide the same level of Personal Information protection as required by this Privacy Policy.

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: (a) enabling you to send content such as contacts and photos between the Service and another’s service; (b) “liking” or “sharing” Culligan’s content; and (c) otherwise connecting 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. 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.

YOUR CHOICES ABOUT TRACKING AND 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.

Analytics and Advertising Technologies

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 www.‌aboutads.info/choices/ (for U.S. choices) or youradchoices.ca/en/tools (for Canadian choices). To learn more about the NAI and your opt-out options for their members, visit 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 implement Google advertising features, such as delivering advertisements, measuring your interests, and personalizing content. For more information on how Google Analytics uses data collected through our services, visit www.google.com/policies/privacy/partners. To opt out of Google Analytics Cookies, visit 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.

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. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.

HOW WE SAFEGUARD PERSONAL INFORMATION

We protect your Personal Information with industry-standard administrative, technical, organizational, and physical security measures. These measures are intended to protect your 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 not intended for children under eighteen (18) years of age. Culligan does not knowingly collect Personal Information of individuals under eighteen (18) years of age. If we learn that we have collected Personal Information of a person under eighteen (18) years of age, we will dispose of that information, or otherwise treat it, in accordance with applicable laws and regulations.

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. For example, we will retain your Personal Information for the period of time required to provide you with the Services, to comply with applicable legal, contractual, tax or accounting requirements, or to defend ourselves from possible legal actions. 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 destroy the same or anonymize it. Where legally permitted, we may also deidentify or aggregate the Personal Information.

INTERNATIONAL TRANSFERS

We are a United States company and we provide our Services subject to United States law. If you are accessing the Services from outside the United States, your Personal Information will be processed in the United States or other countries. We may transfer information to our affiliates, vendors, and business partners around the world, subject to applicable laws, and as a result Personal Information may be transferred to, processed, and stored in states, territories, countries, and other jurisdictions that are outside the jurisdiction where you are located. 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, territories, and jurisdictions may not provide the same privacy protections and their privacy laws may be different than those in the United States or in the country where you are located.

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, good business practices, or otherwise at our discretion subject to applicable laws. If we make any changes, our posted 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.

ADDITIONAL U.S. STATE PRIVACY NOTICE

This section supplements other parts of this Privacy Policy and provides additional information for residents of certain states that provide privacy rights to consumers (each, a “Covered State”), including pursuant to the California Consumer Privacy Act (“CCPA”). If you a resident of a Covered State, you may have the right to submit certain requests relating to your Personal Information, as described below.

Targeted Advertising and Sales

We may share your Personal Information for cross-context behavioral advertising or targeted advertising (“Targeted Advertising”). 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” in some Covered States. To opt out, please email us at CAPrivacyRequest@culligan.com.

Listed below are the categories of Personal Information we disclose for purposes of Targeted Advertising or otherwise “sell” or “share” as defined under applicable privacy laws. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.

Categories of Personal Information:

Contact Information and 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 for Targeted Advertising:

Advertising companies

Analytics companies

Social networks

Purposes for Selling or Sharing for Targeting Advertising:

For marketing, advertising, certain types of analytics, or similar purposes

To show you relevant ads while you browse to internet or use social media

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

Text/SMS Messages

You may opt in to receiving text messages and alerts on the mobile phone number(s) you provide to us. If you opt in, we may send you text messages (a) regarding your account; (b) about our products and promotions (including advertisements, sales, and special offers); (c) to investigate or prevent fraud; and (d) 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.

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 Information 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 may need to authenticate your identity before your request can be processed. For authentication, you may be asked to log into your account or to provide additional pieces of Personal Information that we will match against our records.

Residents of Covered States may have the following privacy rights:

Right to Know and Access. You may have the right to confirm whether we are processing your Personal Information; to access your Personal Information; and to obtain certain information about our processing of your Personal Information, including the categories of Personal Information we have collected about you, the specific pieces of Personal Information we have collected about you, and information about recipients to which we disclose Personal Information.

Right to Data Portability. You may have the right to obtain a copy of Personal Information 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 Information, taking into account the nature of the Personal Information and our purposes for processing it.

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

Right to Opt Out of Sales and Targeted Advertising. 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 Targeted Advertising.

Right to Opt Out of Automated Decision-Making and Profiling. Culligan does not engage in automated decision-making or profiling in furtherance of decisions that produce legal or similarly significant effects. Culligan will accommodate applicable rights under the CCPA related to automated decision-making technology, as applicable.

Right to Appeal. Sometimes we are unable to process requests relating to your Personal Information, 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.

If you choose to exercise any of your privacy rights, we will not discriminate against you.

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

Additional Disclosures for California Residents

Personal Information We Collect. We also process the following categories of Personal Information about California residents:

Personal Records as described in Cal. Civ. Code § 1798.80(e), including telephone number, credit card number, debit card number, physical address, or any financial information.

Inferences About You from Any Other Category of Information We Collect, including information reflecting your preferences, characteristics, trends, or attitudes.

California Employees and Job Applicants. 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 email us at CAPrivacyRequest@culligan.com.

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.

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 emailing us at CAPrivacyRequest@culligan.com.

ADDITIONAL CANADA PRIVACY NOTICE

This section supplements other parts of this Privacy Policy and provides additional information for residents of Canada. If you a resident of Canada, you may have the right to submit certain requests relating to your Personal Information, as described below.

Additional Personal Information We Collect

For residents of Canada that apply for a job with us, we collect: Job Application Information, including contact details such as name, email address, mailing address, and phone number, employment-related information, including résumé or CV, cover letter, work history, and references, educational background, certifications, and qualifications, information provided during interviews or assessments, and any other details submitted as part of the application process. Your Personal Information is collected for the purposes of evaluating and processing job applications, communicating with you, and conducting recruitment activities. All Personal Information will be handled in accordance with this Privacy Policy and applicable laws.

How We Disclose Personal Information Within Our Organization

We disclose Personal Information to our personnel who have a need to know your information in order to perform their duties. Depending on the type of Personal Information handled, this may include personnel in our customer team dealing with customers, customer applications, and after-sale services, customer support team, information technology and security team, product development and infrastructure maintenance team, legal and compliance team, management and administration, marketing and sales, and finance.

How We Safeguard Personal Information

Our third-party service providers are required to protect the confidentiality and security of your Personal Information for the purpose of providing their services to us, to keep the Personal Information secure, and otherwise to handle Personal Information in the same manner as provided in this Privacy Policy, as required by applicable laws.

We use standard industry practices to protect your Personal Information, including data encryption of information in transit and at rest, multi-factor authentication mandatory for all access to our systems, continuous monitoring and use of tools to detect and respond to security incidents, restricted access policy where access is granted based on the needs of our personnel, staff training to provide awareness of data protection best practices, firewalls, SSL encryption, and system redundancies.

We are committed to protecting your Personal Information and have established governance policies and practices to ensure its security and proper management throughout its life cycle. Our governance policies and practices include:

Framework for Retention and Destruction: Guidelines for the secure retention and destruction of your Personal Information, ensuring that it is kept only for as long as necessary for the purposes for which it was collected or as required by law.

Roles and Responsibilities: Clearly defined roles and responsibilities for our personnel to safeguard your Personal Information at every stage of its life cycle, from collection to destruction.

Complaint Process: A transparent process for handling complaints regarding the protection of your Personal Information, ensuring that concerns are addressed promptly and effectively.

Marketing and Advertising

Any use of your Personal Information for marketing and advertising purposes will be in accordance with your marketing preferences and consent choices. You may opt out of receiving marketing and advertising materials at any time through the Services and adjust your marketing preferences or follow the unsubscribe instructions included in each marketing communication.

If required by applicable law, we will ask for your express consent to collect your Personal Information for the purpose of sending you commercial electronic messages. To ensure compliance, we will keep a record of your consent to this effect, including the date, time, and method of consent in order to comply with applicable legislation. You have the right to refuse to provide consent or withdraw your consent to receive commercial electronic messages in case you change your mind. To withdraw, 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

We will ask for your express consent to collect your Personal Information for the purpose of sending text messages and alerts on the mobile phone number(s) you provide to us. If you opt in, we may send you text messages: (a) regarding your account; (b) to investigate or prevent fraud; and (c) to alert you in the event of an issue with any of your purchases. 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.

Privacy Rights

If you are a resident of Canada, you may have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please email us at CAPrivacyRequest@culligan.com. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you may be asked to log into your account or to provide additional pieces of Personal Information that we will match against our records.

Residents of Canada may have the following privacy rights:

Right to Access and Data Portability. You may have the right to access your Personal Information and to obtain a copy of Personal Information you provided to us in a portable format.

Right to Correct, Update, or Delete. You may have the right to request that we correct inaccuracies in your Personal Information, update, or delete the same.

Right to Withdraw Consent. When your Personal Information is processed based on your consent, you have the right to withdraw your consent at any time. Such withdrawal will be applied to any future processing of your Personal Information.

Right to opt out of marketing communications, even if you have previously consented to receiving them. You may opt out at any time.

Right to de-indexation, re-indexation, or cessation of dissemination of your Personal Information.

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

If you wish to exercise any of your privacy rights, such as access rights, the right to correct or delete your Personal Information, get a portable copy of your Personal Information, exercise any other privacy right, ask any questions, including about this Privacy Policy, or file a complaint regarding the handling of your Personal Information, you can contact our Privacy Officer via email at CAPrivacyRequest@culligan.com, or by calling us toll-free at 877-225-8757. Our Privacy Officer can also be reached at 9399 West Higgins Road, Rosemont, IL 60018.

We will respond to your request as soon as possible but no later than within thirty (30) days from the receipt of your request. Should we require additional information to be able to respond to your request, we will notify you as soon as possible. Furthermore, in the event we are unable to respond to your request for whatever reason, we will be sure to inform you in writing.

Cross-Border Transfer of Personal Information

We will disclose your Personal Information to our service providers that may be located outside of Canada. As a result, your Personal Information may be transferred to and processed in countries outside of Canada.

If you live in Quebec, your Personal Information may be communicated to entities outside of the province of Quebec. Our affiliates, subsidiaries, and related entities, as well as our third-party service providers and partners may operate around the world. This means that when we collect your Personal Information, such information may be processed in any of these countries and, accordingly, may be accessible to courts, law enforcement, and national security authorities of those countries.

If you have any questions or wish to obtain further written information about our policies and practices with respect to the collection, use, disclosure or storage of your Personal Information by service providers, affiliates, or related entities outside of Canada, you may contact our Privacy Officer at CAPrivacyRequest@culligan.com.

Right To Withdraw Your Consent

You have the right to withdraw your consent at any time for purposes that are unrelated to the provision of the Services, such as commercial electronic communications, marketing and promotion, personalized advertising, or any other purposes that are not essential for the rendering of the Services to you. You may withdraw consent as described in the Your Choices about Tracking and Communications section above or by emailing CAPrivacyRequest@culligan.com. To withdraw consent to marketing messages, you can unsubscribe by following the link in each message.

Material Changes to this Privacy Policy

Where required by law, we will provide notification of material changes to this Privacy Policy at least thirty (30) business days prior to the change taking effect. Where appropriate, we may also email users who have opted to receive communications from us notifying them of changes to this Privacy Policy. If we are required by applicable laws to obtain your consent to any material changes to this Privacy Policy, we will do so before such changes take effect.