Culligan International Company Privacy Policy

NEW PRIVACY POLICY

Effective Date: 1/1/2010.
  
To print this Privacy Policy (“Privacy Policy”), click here.

Privacy Policy Scope

Welcome!  An overview of this Culligan Privacy Policy is provided below.  To see the full text, click on the links.  This Privacy Policy applies to your use of any online services (e.g., website, software, or mobile app) that posts a link to this Privacy Policy, regardless of how you access or use it.  Click here  to view our Terms of Use. 

Quick Links

We have summarized some (but not all) of the main topics of this Privacy Policy below. The complete provisions, and not the headings or summaries govern. 
 

FULL CULLIGAN PRIVACY POLICY

Thank you for visiting an online service (e.g., website or mobile app) that posts a link to this Privacy Policy (“Service”) owned or operated by Culligan International Company (“Culligan”, “we”, or “us” or “our”).   This Privacy Policy will provide you with information as to how Culligan collects, uses, and shares information about you, including the choices Culligan offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to Culligan’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). 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.
 
By visiting or otherwise using the Service, you agree to the Service’s Terms of Use and consent to Culligan’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service.  If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.

 

1. INFORMATION WE COLLECT  
   1. Information about You that You Provide. Culligan, and/or its Service Providers (defined below), may collect information you provide directly to Culligan and/or its Service Providers via the Service.  For example, Culligan collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service.  In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.  For more information on Third-Party Services’ data collection and practices click here.   For more information on Service Provider data collection and practices click here.
      
      Information Culligan, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personal Information”); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“Demographic Information”).  Except to the extent required by applicable law, Demographic Information is “non-Personal Information” (i.e., data that is not Personal Information under this Privacy Policy).  In addition, Personal Information, including, without limitation, Culligan-Collected PI (defined below), once “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements including through anonymization, pseudonymization, and/or hashing) is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law.  However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personal Information is combined by or on behalf of Culligan with Personal Information Culligan itself collects directly from you on the Service (“Culligan-Collected PI”), Culligan will treat the combined data as Culligan-Collected PI under this Privacy Policy.
       
   2. Information Collected Automatically. Culligan, its Service Providers, and/or Third-Party Services 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).  Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Culligan with Culligan-Collected PI, Culligan does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Culligan-Collected PI.  For more information on Third-Party Services’ data collection and practices click here.   For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
      
      The methods that may be used on the Service to collect Usage Information include:
       
      • Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
         
      • Information Collected by Cookies and Other Tracking Technologies:  Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
         
        • Cookies 
          A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device.  HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them.  To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.  The Service may associate some or all of these types of cookies with your devices.
           
        • Web Beacons (“Tracking Pixels”)  
          Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
           
        • Embedded Scripts
          An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Culligan’s web server, or from a third party with which Culligan works and is active only while you are connected to the Service and deleted or deactivated thereafter.
           
        • Location-identifying Technologies
          GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including ads, based on your location.If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties. Our dealer locator feature may access and use information about your device location (such as based on IP address or GPS, as applicable), or your account information, to suggest appropriate store locations.  Our Service content may be personalized based on various information we may have about you to try to provide you with more location-relevant content.
           
        • Device Recognition Technologies.
          Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
           
        • In-App Tracking Methods
          There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings.  Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices.
           
      • Some information about your use of the Service and certain third-party services may be collected using Tracking Technologies across time and services and used by Culligan and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain third-party services.  See Section 11 regarding certain choices regarding these activities.
        
        Culligan is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
         
   3. Information Culligan Collects From Other Sources. Culligan may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Culligan-Collected PI.  Notwithstanding anything to the contrary, except to the extent such data combined by or on behalf of Culligan with Culligan-Collected PI, this Privacy Policy is not intended to limit Culligan’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personal Information), and such data will only be treated as Culligan-collected PI to the extend it is combined with Culligan-collected PI. Culligan is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.  
      
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2. HOW WE USE THE INFORMATION WE OBTAIN.
   Culligan may use information about you, including Culligan-Collected PI and other Personal Information, for any purposes not inconsistent with Culligan’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:
    
   • Allow you to participate in the features we offer on the Service;
      
   •  Facilitate, manage, personalize, and improve your online experience;
      
   •  Process your registration, manage your account and/or upload your User Generated Content (“UGC”). (For more information on how UGC is treated under the Service’s Terms of Use click here. For more on the public nature of UGC, see Section 5);
      
   •  Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
      
   •  Culligan Related Parties’ marketing and other purposes;
      
   •  Improve the Service and for any other internal business purposes;
      
   •  Tailor our content, advertisements, and offers;
      
   •  Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;
      
   •  Determine your location and manage digital content rights (e.g., territory restrictions); and
      
   •  Prevent and address fraud, breach of policies or terms, and threats or harm.
     
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3. INFORMATION WE SHARE WITH THIRD PARTIES.
   Culligan may share non-Personal Information, and Personal Information that is not deemed Culligan-Collected PI hereunder (provided that Culligan is aware of no restrictions of Culligan’s use, if any), with third parties, including without limitation, any Culligan dealers that are authorized by Culligan to sell Culligan services or products (“Culligan Related Parties”) for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personal Information, including Culligan-Collected PI, to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the Personal Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices.  Culligan’s sharing of Culligan-Collected PI is, however, subject to the following:
    
   • Marketing:  Subject to your communications choices explained in Section 11.D, and the rights of California residents explained here, we may use your Personal Information to send you marketing communications.  Absent your consent (which may be by means of opt-in, your election not to opt-out, or a third party interaction described in the next bullet point), however, Culligan will not share your Culligan-Collected PI with third parties, other than Culligan Related Parties, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
      
   • Your Disclosure or Consent:  As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Culligan-collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties.  For instance, when you request additional information about our products and services via our Service, you are directing us to pass your Personal Information along to authorized Culligan dealers to respond to your inquiry.  Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Culligan.
      
   Culligan may also share any information about you (including, without limitation, Culligan-Collected PI) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:
    
   • Culligan’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on Culligan’s behalf, provided however, Culligan does not authorize its Service Providers to use Culligan-Collected PI provided by Culligan to the Service Providers to send you direct marketing messages other than related to Culligan and Culligan Related Parties absent your consent.  For more information on choices Service Providers may offer you click here.
      
   • To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
      
   • If Culligan believes your actions are inconsistent with Culligan’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Culligan, the Service or its users, or any third party.
      
   In addition, Culligan may share your Culligan-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Culligan assets, or transfer of all or a portion of Culligan’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
   
   EEOC / Affirmative Action Reporting.  In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity).  Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
   
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4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.
   Culligan may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information.  If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to Culligan, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy.  Please review those rules carefully.  
   
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5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.
   The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information.  If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Culligan.  Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Information included in UGC is not subject to Culligan’s usage or sharing limitations, or other obligations, regarding Culligan-Collected PI or other Personal Information under this Privacy Policy or otherwise, and may be used and shared by Culligan and third parties to the fullest extent not prohibited by applicable law.  Culligan encourages you to exercise caution when making decisions about what you disclose in such public areas.  For more information on how UGC is treated under the Service’s Terms of Use click here. California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.
   
   Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Culligan relies on you to only send to people that have given you permission to do so.  The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Culligan for any other marketing purpose unless Culligan obtains consent from that person.  Your contact information and message may be included in the communication. 
   
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6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
   The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.
   
   Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”).  Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Culligan’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service).  If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5 ) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Culligan or other Culligan Related Parties in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Culligan and Culligan Related Parties.  Also, both Culligan and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
   
   Culligan may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services.  Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”).
   
   Culligan may use Google Analytics, Adobe Analytics or other Service Providers for analytics services.  These analytics services may use cookies and other Tracking Technologies to help Culligan analyze Service users and how they use the Service.  Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage.
   
   Except to the extent we combine information we receive from Service Providers, Third-Party Services, or other third parties with Culligan-Collected PI, in which case Culligan will treat the combined information as Culligan-Collected PI under this Privacy Policy (see Section 1(c)), data obtained by Culligan from a third party, even in association with the Service, is not subject to Culligan’s limitations regarding Culligan-Collected PI under this Privacy Policy, however such data remains subject to any restrictions imposed on Culligan by the third party, if any.  Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with Culligan, the types of information shared, and your choices on what is visible to others on Third-Party Services.
   
   Culligan is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.  See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.
   
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7. DATA SECURITY AND MONITORING.
   Culligan takes reasonable measures to protect Culligan-Collected PI (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Culligan does not guarantee the security of your information collected through the Service.
   
   To help protect you and others, Culligan and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Culligan-Collected PI and other Personal Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these documents; and otherwise to protect the rights and property of Culligan Related Parties, third parties, and other users.  Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service.  If you do not consent to these conditions, you must discontinue your use of the Service.
   
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8. INTERNATIONAL TRANSFER.
   Culligan is based in the U.S. and the information Culligan and its Service Providers collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S.  Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.
   
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9. CHILDREN’S PRIVACY.
   The Service is intended for a general audience and not directed to children less than 13 years of age.Culligan does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA.  If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Culligan here , detailing where the content or information is posted and attesting that you posted it.  Culligan will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Culligan does not control.
   
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10. ACCESSING AND CHANGING INFORMATION.
    Culligan may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Culligan-Collected PI, and potentially certain other information about you (e.g., profile and account information).  Culligan will make good faith efforts to make requested changes in Culligan’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Culligan’s databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter.  Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
    
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11. CHOICES:  TRACKING AND COMMUNICATIONS OPTIONS.
    1. Tracking Technologies Generally. Regular 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.  Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies.  For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html.  Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. 
       
       Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app.  To uninstall an app, follow the instructions from your operating system or handset manufacturer.  Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective. 
       
       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, Culligan currently does not alter Culligan’s practices when Culligan receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Culligan is not responsible for the completeness or accuracy of this third party information.  Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies.  Culligan is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms.   For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
        
    2. Analytics and Advertising Tracking Technologies. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.  You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.” 
       
       You may choose whether to receive some Interest-based Advertising by submitting opt-outs.  Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.  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/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads).  Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.  Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads.  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).  Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.  Culligan supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf) and expects that ad networks Culligan directly engages to serve you Interest-based Advertising will do so as well, though Culligan cannot guaranty their compliance. Culligan is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. 
       
       In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”).  This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the third-party services.  For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services.  We are not responsible for these Third-Party Services, including without limitation their security of the data.  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, and find out what options Facebook offers you to control such ads.  If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
        
    3. Mobile Apps. With respect to Culligan’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app.  Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:
       
       Android:
       For Android 6.0 and above:
       - https://support.google.com/googleplay/answer/6270602?hl=en 
       For earlier versions of Android:
       - https://support.google.com/googleplay/answer/6014972 
       iOS:
       - https://support.apple.com/en-us/HT207056
        
    4. Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from Culligan at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from Culligan to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.  If you opt-out of only certain communications, other subscription communications may continue.  Even if you opt out of receiving promotional communications, Culligan may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Culligan’s ongoing business relations. Except in connection with Corporate Transactions, to prospectively opt-out of our sharing of your Company-Collected PI, other than with Culligan Related Parties, for their own direct marketing purposes, contact us here.
        
    5. Cross-Device Data.  To learn more about how you can exercise choices regarding certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices. 
        
    6. Nevada Residents.  Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. Although we do not currently “sell” “covered information” of Nevada “consumers” as those terms are defined under that law, you may contact us here and provide your name, Nevada resident address, and email address to be verified and exercise your opt-out rights in the event we do sell covered information under that law in the future. If you change your email address or other contact information, contact us in the same manner to update your contact information to help facilitate your opt-out. Changing your contact information elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada opt-out information and we will only use the information provided to our opt-out program for managing opt-outs.  It is your responsibility to keep your opt-out information current. If after opting-out you direct us to share you covered information with others, we will do so regarding of your prior opt-out.
       
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12. YOUR CALIFORNIA PRIVACY RIGHTS.
    California residents have certain additional rights as more fully detailed in our California Privacy Notice. In the event of a conflict between that notice and this policy, that notice will govern California resident’s privacy rights.
    
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13. CHANGES TO THIS PRIVACY POLICY
    We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use.  However, we will not treat your previously collected Culligan-Collected PI, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
    
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14. CONTACT CULLIGAN.
    If you have any questions about this Privacy Policy, please contact Culligan here or at 9399 W. Higgins Rd., Ste 1100, Rosemont, IL 60018, USA (Attention: Privacy Office).
    
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      Culligan 2019.  All Rights Reserved. ©
     

Privacy Policy Table of Contents

Click on the links to navigate to the sections:

1. Information We Collect 
   1. Information about You that You Provide
   2. Information Collected Automatically
   3. Information Culligan Collect From Other Sources
2. ​How We Use The Information We Obtain
3. Information We Share With Third Parties
4. Sweepstakes, Contests, and Promotions
5. Information You Disclose Publicly or to Others
6. Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics
7. Data Security and Monitoring
8. International Transfer
9. Children’s Privacy
10. Accessing and Changing Information
11. Choices: Tracking and Communications Options
    1. Tracking Technologies Generally
    2. Analytics and Advertising Tracking Technologies  
    3. Mobile Apps
    4. Communications
12. ​Your California Privacy Rights
13. Changes to this Privacy Policy
14. Contact Culligan