Connect Mobile App Privacy Policy

Privacy Policy Effective January 30, 2017

This Culligan Connect Mobile App Privacy Policy (“Privacy Policy”) is presented by Culligan International Company (collectively, “Culligan”, “we”, or “us” or “our”) to you in order to help you make an informed decision about using the Culligan Connect mobile app, and any other Culligan online services that post this Privacy Policy (collectively the “Culligan Connect Service”), and to explain to you our data practices in connection therewith.  This Privacy Policy does not apply to our data practices outside of the Culligan Connect Service (e.g., offline, other apps or web sites and our products except to the extent Associated Products (defined below) are connected to the Culligan Connect Service).  By using the Culligan Connect Service, you are consenting to have your personally and non-personally identifiable data transferred to and/or processed in the United States and to our data practices as set forth in this Privacy Policy. Do not use Culligan Connect Service, and uninstall service downloads and applications, if you do not agree with this Culligan Connect Service Privacy Policy and Terms of Use (https://www.culligan.com/culligan-terms-and-conditions/connect)or any other policies or Additional Terms posted on the Culligan Connect Service.

1. 1. The Information We Collect from You
      1. Non-Personally Identifiable Information
         When you use the Culligan Connect Service, we may automatically collect certain non-personally identifiable information (“Non-PII”) from and about you and your devices. This may include certain information about your computer, browser or mobile device (including device type, operating system version, device language, country and time zone) and information about your linked or otherwise associated Culligan water treatment devices (“Associated Products”)(e.g., product performance information), as well as about your usage of the Culligan Connect Service and Associated Products. To the fullest extent permitted by applicable law, we treat device identifiers as Non-PII.  Without limiting the generality of the forgoing, data (including PII and Service-collected PII as defined below) once “de-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements) is also non-PII and may be used and shared without obligation to you, except as prohibited by applicable law.
      2. Personally Identifiable Information
         The Culligan Connect Service is only made available if we have certain information about you. To register as a user and access these services, you will, from time to time, be asked to submit personal information about yourself that directly identifies you individually (“PII”).  PII collected by Culligan via the Culligan Connect Service is “Service-collected PII.” For instance, we collect and process the following Service-collected PII in connection with Culligan Connect Service registration: To the extent we combine other PII, or non-PII, with Service-collected PII, the combined data will also be treated as Service-collected PII.  However, such data once disassociated with Service-collected PII will not be subject to our limitations under this Privacy Policy regarding Service-collected PII. To the extent we obtain your PII other than via our own collection of it via the Culligan Connect Service, and it is not combined with Service-collected PII, such is not subject to our limitations regarding Service-collected PII under this Privacy Policy; however, such data remains subject to any restrictions imposed on Culligan by other applicable privacy policies or by third party sources, if any.
         • Name
         • E-mail address
         • Phone number
      3. Use of 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 Culligan Connect Service, your use of the Associate Products and/or texts, e-mails, and/or push notifications associated with the Culligan Connect Service, including information about your usage behavior.  We are giving you notice of the Tracking Technologies so that your consent to encountering them is meaningfully informed.  If you do not consent, do not use the Culligan Connect Service.  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 “Do Not Track” signal from a visitor’s browser.  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.  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 Tracking Technologies, some parts of the Culligan Connect Service may not work and that when you revisit the Culligan Connect Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
      4. Privacy of Children
         The Culligan Connect Service is intended for a general audience 18 and over and not directed to children less than 13 years of age. We do not intend to collect personal information as defined by the U.S. Children’s 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.

1. Use of Information CollectedWe may use information about you, including Service-collected PII, other PII and non-PII, for any purposes not inconsistent with our statements under this Privacy Policy or otherwise made at the time of collection, and not prohibited by applicable law, including, without limitation, the following: However, we will not use your service-collected PII to send you unsolicited marketing messages and will obtain your sent to receive promotional messages before doing so.
   • Allow you to participate in the features we offer on the Culligan Connect Service;
   • Facilitate, manage, personalize, and improve your service and product experience;
   • Process and administer your registration and manage your account;
   • Send you alerts, transact with you, provide services or information you request, respond to your comments, questions and requests, and send you notices;
   • Facilitate service requests through local Culligan dealers and service representatives;
   • Improve our products and services and for any other internal business purposes;
   • Fulfill other purposes disclosed at the time you provide PII or otherwise where we are legally permitted or are required to do so; and
   • Prevent and address fraud, breach of policies or terms, and threats or harm.
   1. However, we will not use your service-collected PII to send you unsolicited marketing messages and will obtain your sent to receive promotional messages before doing so.
2. Disclosure of your Personal Information
   1. Third Parties
      We may share your Service-collected PII, and/or other data about you, with Culligan dealers and service representatives for the purposes of (1) providing you the services you request; (2) resolving your support inquiries; and (3) otherwise in connection with providing you services, and responding to your inquiries, in connection with the Culligan Connect Service and/or the Associated Products.  However, we do not sell, share, or rent your Service-collected PII to third parties for their own direct marketing purposes unless you have specifically consented to our doing so (which permission we may seek from time-to-time), except in connection with Corporate Transactions (e.g., a merger) described below.
   2. Compliance with Law
      Culligan reserves the right, as permitted by applicable law, to disclose your Service-collected PII, and/or other data about you, without prior notice to you, as required by law or when we believe that disclosure is necessary to comply with a law, regulation, or any legal request (e.g. court order or subpoena) served on us.  Furthermore, as permitted by applicable law, we may share your Service-collected PII, and/or other data about you, when we believe it is necessary or appropriate to address fraud or other illegal or prohibited activity perpetrated through the Culligan Connect Service, prevent imminent bodily harm, and/or to cooperate with law enforcement or government requests.  However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
   3. Service Providers
      We may employ service providers and other companies and individuals to perform functions and provide services on our behalf (such as data storage, hosting, etc.).  These entities may have access to your Service-collected PII, and/or other data about you, in connection with their services to Culligan.  However, we do not authorize our service providers to use Service-collected PII for their own direct marketing purposes.
   4. Corporate Transactions
      In addition, and notwithstanding anything to the contrary, we may share your Service-collected PII (as well as your other PII and your non-PII), in connection with or during negotiations of any proposed or actual merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Culligan’s assets, or transfer of all or a portion of our business to another company (“Corporate Transactions”).
3. Changing or Deleting Your InformationIf you are a registered user, you may review, update and/or correct the Service-collected PII provided by you as part of your account registration by visiting the “Settings” of the Culligan Connect Service app. If your e-mail address or mobile number changes, you are expected to update it immediately in your registration information.  We may maintain your registration information even if you change or delete it, or uninstall the Culligan Connect Service app, for business record and other purposes, as permitted or required by applicable law.  Your registration information changes may take time to update, and updates may not properly process, so be sure to check back to confirm your registration changes were updated as requested.
4. CommunicationsBy installing the Culligan Connect Service app, and/or registering for the Culligan Connect Service, you consent to receive communications, including text (by use of autodialer or otherwise), mobile push notifications and e-mails related to your use of the Culligan Connect Service and/or Associated Products (“Alerts and Notices”).  However, we will not use Service-collected PII to send you unsolicited promotional offers unless you consent.  You may also receive promotional communications from us outside of the Culligan Connect Service unrelated to your Service-collected PII (“Outside Communications”).  Any opt-out from any Outside Communications will not affect Alerts and Notices and your Alert and Notice communications preferences will not affect Outside Communications.  You can change your Alerts and Notices communications preferences in the “Settings” of the Culligan Connect Service app.  We will typically try to honor your preferences except that we reserve the right to send you Alerts and Notices by mobile push notifications and e-mail to the extent we deem it reasonably necessary to reach you, and we may respond to your inquiries by the same method you made an inquiry even if that method has been turned off in your preferences.  Notwithstanding your withdrawal of consent to Alerts and Notices by text using an autodialer, you consent to receive a text confirming receipt of a withdraw request and to receiving texts in reply to text inquiries or upon any new consent to receive text Alerts and Notices via text.
5. SecurityWe implement reasonable measures to protect the PII we collect and store, taking into consideration the types of risks we face and the reasonable protections available to us. No method of protecting information is 100% secure, and we cannot guarantee its absolute security.
6. Information for Users Outside the United States
   If you are visiting Culligan Connect Service from outside the United States, please be aware that information we collect through Culligan Connect Service will be transferred to and processed stored on servers and otherwise in the United States. By using Culligan Connect Service, you acknowledge and consent to the transfer and processing of your Service-collected PII and other information in the United States as described in this Privacy Policy. Please be aware that the data protection laws and regulations applicable to your non-PII and PII transferred to the United States may be different from the laws in your country of residence.
7. Your California Privacy RightsCalifornia’s Shine the Light Act (“STL Act”) permits customers in California to request certain details about how their certain of their information is shared with third parties when the information is shared for those third parties’ own direct marketing purposes. We do not share California customers’ personal information, as defined under the STL Act, collected by us via the Culligan Connect Service with third parties for their own direct marketing purposes unless the customer has specifically consented to our doing so (which permission we may seek from time-to-time), except in connection with Corporate Transactions (e.g., a merger) described above.  If you are a California resident, you may request further information about our compliance with this law by contacting us at customerservice@culligan.com. Any such request must include “California Privacy Rights Request” in the subject line, or first line of the body, and include your name, street address, city, state, and ZIP code.
8. Data Practices of Third PartiesWhen you click on links to websites or other services outside of the Culligan Connect Service, leave the Culligan Connect Service, or access third party services via the Culligan Connect Service (e.g., social media plug ins, APIs, etc.)(collectively “Third Party Service(s)”) third parties may place their own Tracking Technologies on or in connection with your device, and may collect data from or about you.  We may have no control over these third parties and take no responsibility for the technologies they employ or their services or practices.  To learn how a Third Party Service collects and uses your information, you should read the privacy policy of that service.
9. Changes to Privacy PolicyCulligan reserves the right to change this Privacy Policy at any time.  Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Culligan Connect Service indicates your consent to the privacy policy posted at the time of use.  However, we will not use your previously collected Service-collected PII, 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.
10. QuestionsFor questions or concerns regarding this Privacy Policy please contact: customerservice@culligan.com.

This Privacy Policy is effective as of January 30, 2017.