This Policy describes Spectrum’s practices with respect to information we collect and receive from users of our websites, mobile applications, and social media pages (each, a “Site”), recipients of our emails, and in the process of fulfilling orders and performing customer service (together with the Sites, the “Services”), including the categories of information collected, how that information is used, and with whom that information is shared.
By accessing, using, and requesting the Services, you agree and consent to the collection, maintenance, use, and disclosure of your Personal Information by Spectrum. If you do not agree to the terms of this Policy or do not consent to the collection, maintenance, use, and disclosure of your Personal Information (as defined below) by Spectrum as described within this Policy, you should leave the Site and stop using and/or requesting our Services immediately.
PRIVACY OF CHILDREN
The Sites are general audience websites. We do not intentionally collect Personal Information from users of a Site who are under the age of thirteen (13). If we become aware that a user of our Site is under the age of thirteen (13) and has provided Personal Information to us by using our Site (e.g., placing an order or entering a sweepstakes, contest or other promotion, etc.), we will remove that child’s Personal Information from our files. Where necessary, we may use such information to provide notice to the parents of the users under the age of thirteen (13) who are using a Site.
WHAT INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
"Personal Information" is any information that identifies, relates to, or describes, directly or indirectly, a particular individual, such as your first and last name, your postal address and zip code, your e-mail address, your telephone number, your hobbies and interests, and/or information regarding your purchases.
We collect Personal Information through our Sites, when delivering products, customer service and otherwise, and use it for typical business management, operational and commercial purposes (including to defend and protect us and others from harm or legal claims, and as required by applicable law) and as described more specifically below:
Submitted through a Site. We may collect Personal Information from you if you register with our Site, sign up for our newsletter, purchase products on our Site, enter a sweepstakes, contest, or other promotion, submit a rebate or coupon request, or otherwise voluntarily provide such information to us (e.g., via our “Contact Us” webpage or in connection with ratings, reviews, requests for advice, suggestions, testimonials, or any user-generated content, such as photographs and/or videos).
· Personal identifiers. We receive personal identifiers (such as your name, phone number, email address, billing address, shipping address, password, device ids, and IP address) and use them to respond to requests, send you newsletters and other requested information, process rebate or coupon requests, fulfill and deliver orders for products and services, deliver product samples, process returns or exchanges, contact you or others about an order or delivery, facilitate surveys, product reviews, product ratings, promotions, sweepstakes, and contests, manage accounts and preferences, manage accounts, application troubleshooting, communicate with you for marketing purposes for Spectrum or on behalf of its affiliated companies or marketing partners, and facilitate personalized online advertising and informational communications (such as for warranty and product issues). We will also create a customer number when you make a purchase so we can identify you in our systems.
· Personal characteristics. We receive personal characteristics (such as your date of birth and gender) when you submit it to sign up to receive newsletters and offers or to participate in a contest. We use such information to send you information we think is relevant to you, personalized online advertising, and determine eligibility for contests.
· Financial information. We may receive your payment card related information when you make payments to us, and we will provide it to our payment processor. We also receive information about completed purchases from our payment processor when you make a purchase.
· Commercial transaction information. We collect and generate commercial transaction information (such as records of products and services purchased, frequency of delivery, and quantity of items purchased) when you make purchases on a Site. We use this information to deliver and fulfill your orders, process your returns or exchanges, improve our service and product offerings, tailor our marketing efforts and administer accounts, and for internal operations and reporting purposes.
· Message and product/Site review content. We collect the messages you submit through contact, sign-up, surveys, purchase and product review forms on a Site. We use this information to respond to and fulfill your requests, better understand your needs and preferences, enhance and personalize our product offerings to you and improve the Sites and our service and product offerings.
· Inferences from the information listed above. We will use the information listed above to draw inferences about your preferences (such as your preferred brands) to help us provide you with personalized content and offers and help us develop and provide better products and services.
You may choose not to provide your Personal Information to us by leaving the Site immediately. Please note that if you do not provide such information, you will not be able to place an order with us or enter any of our sweepstakes, contests or promotions, and we may not be able to send you our newsletter, process your rebate or coupon request, and/or respond to your “Contact Us” inquiry.
Received to Deliver an Order. When you submit an order for Spectrum’s products from a retailer or other company, the retailer or other company may send us personal identifiers and commercial transaction information so we can ship the products you purchased directly to you and for the purposes listed above.
Automatic Collection of Device and Site Usage Information. We and our service providers and third-party partners, such as advertising networks, social media widgets, and analytics providers, may automatically collect Personal Information using cookies and similar technology when you use a Site and our emails. We use this information to provide and improve our Sites, systems, and order processing, for anti-fraud purposes, to tailor your experience on our Sites and our marketing efforts, and to create aggregate internal reports on website usage and activity, such as views of certain products. These additional categories may consist of:
· Online identifiers. We and our service providers and third-party partners may collect your IP address, device advertising id, and other device and online identifiers when you use the Sites. In addition to the uses described above, we may use this information to send push notifications to our mobile applications installed on your device (if you enable them) and determine the city, state and country in which you are located.
· Website and mobile application activity and technical information. We and our service providers and third-party partners may monitor and collect Site usage activity information and device characteristics, such as Site clicks, content and page views, feature usage, the website each visitor visited prior to our Site, the search engine and search terms that you used, and information about your previous visits to our Site, domain type, browser version, app or operating system version, the length of your visit or use, your Internet service provider, the language settings on your computer, and/or certain software (e.g., Java support).
· Inferences from the information listed above. We and our service providers and third-party partners will use the information listed above to draw inferences about your preferences (such as your preferred brands) to help us provide you with personalized content and offers and help us develop and provide better products and services.
An “HTML Cookie” is a small amount of data that is sent to your browser from a webserver and stored on your computer’s hard drive. HTML Cookies provide a means for websites that you visit to keep track of your online usage patterns and preferences. Among other things, HTML Cookies help us identify returning users and customize our services to a user’s needs. By understanding which areas of the Site a user has visited, HTML Cookies allow us to present information, products, and specials that may be of the user’s interest.
Spectrum may also use “Flash Cookies,” which tracks a person's Internet use across multiple websites and are not deleted or controlled by users in the same manner as standard HTML Cookies. You can see a list of cookies and similar technology used on a Site by clicking on the Cookie Notice link in the footer of the Site.
As a visitor to the Sites, you may have the option to deactivate the ability of us and our third-party partners to analyze your browsing and purchasing behavior on our website. We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/technologies/partner-sites. You may learn more about advertising networks and opt out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here:
· Website Opt-Outs
· Network Advertising Initiative: http://www.networkadvertising.org/choices/
· Digital Advertising Alliance: http://www.aboutads.info/choices/
· App Opt-Out: http://youradchoices.com/appchoices
You may also be able to change your mobile device settings to opt out of personalized advertising through apps. For example, for iOS mobile devices, go to “Settings” from your device’s home screen; scroll down to “Privacy”; select “Tracking”; and turn off “Allow Apps to Request to Track.” For Android mobile devices, go to “Google Settings” on your device; select “Google” and then “Ads”; and check the box labeled “Opt Out of Interest-Based Ads” or “Opt out of Ad Personalization.”
When you opt out of personalized advertising, you may continue to see online advertising on the Sites and/or our ads on other websites and online services. Since this opt-out relies on cookies, if you delete your cookies, you will need to opt-out again.
De-identified or Aggregated Information. We de-identify and/or aggregate data we receive and may use and disclose it for any business or commercial purpose.
HOW DO WE SHARE THE INFORMATION WE COLLECT?
We share any of the categories of Personal Information we receive (listed above) for our business and commercial purposes and as more specifically described below.
Service providers. We share any of your Personal Information with service providers that provide services to us, including to help us conduct maintain our databases and Sites, administer emails, facilitate product registration, and perform marketing and advertising.
Third parties. We also share any of your Personal Information with third parties to help us provide products and services to you such as fulfilling and delivering orders, processing payments, facilitating and publishing product ratings and reviews, social media functions, product sampling, and administering drawings or contests. In these situations, you are using and directing us to intentionally disclose Personal Information (including personal identifiers and financial information) so our products and services can be provided to you and we can respond to your requests.
Affiliates.We may share any of your personal identifiers (such as name, mailing address, phone number, and email address) and commercial transaction information with affiliated and subsidiary companies so we can more efficiently operate our business and they can provide services to you and us.
Public. If you choose to participate in a survey, product review or rating, or rate a review as helpful or not helpful, you may be providing information to a third party that we use to process product ratings and reviews. Product ratings and reviews may be published on the Sites, in emails, on television, and on social media platforms. Published ratings and reviews may identify the author’s review nickname and locale. In these situations, you are using and directing us to intentionally disclose Personal Information (including personal identifiers) so your product ratings and reviews can be available to the public.
Merger, sale, or other asset transfers. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another business unit (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), we will provide any Personal Information (including commercial transaction information) associated with each such business unit to the persons and/or entities assuming control of such business unit and our advisors or as otherwise necessary to complete the transaction as permitted by law or contract.
Do Not Track Disclosure. . Spectrum does not track users’ behavior across websites for the purpose of serving targeted ads, and, the Site does not respond to browser Do Not Track (DNT) signals.
IS THE INFORMATION COLLECTED SECURE?
YOUR PRIVACY RIGHTS
Certain jurisdictions impose specific legal requirements and grant data subject rights with respect to Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete Personal Information we have about you, or to consent or withdraw consent to certain uses or sharing of Personal Information. When you make a request, we may require that you provide information and follow procedures so that we can validate a request you make before responding to it. We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event. As permitted by applicable law, we may charge a reasonable fee to help cover the cost of responding to your request, and we will inform you of the fee before completing your request. Specific provisions for some jurisdictions are set forth below.
For other jurisdictions, please direct your request to the address below.
Spectrum Brands, Inc.
Attention: Legal Department
3001 Deming Way
Middleton, WI 53562-1431
CALIFORNIA NOTICE AND PRIVACY RIGHTS
We do not sell Personal Information, and we have not sold Personal Information since January 1, 2020, the date the CCPA went into effect. We also do not rent, sell, or share Personal Information (as defined by California Civil Code §1798.83) about you that we collect on the Services with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission.
We permit third-party partners to track visitors to the Services and the activities of those visitors on the Services over time, and they may track those visitors across other websites and online services over time, if those websites and apps also use the same partners. In these situations, you are using and directing us to intentionally disclose Personal Information (including personal identifiers) to those third-party partners to provide you with personalized advertising perform those services. You can learn more information about the collection of Personal Information by service providers and third-party partners who process information collected by cookies and similar technologies that we permit them to use on the Sites by clicking on the Cookie Notice link in the footer of the Site.
A California consumer has the following rights: to request additional information about our data collection, use, disclosure, and sales practices in connection with the consumer’s Personal Information; to request the specific Personal Information collected about the consumer during the previous 12 months; and to request the deletion of the Personal Information we have about the consumer. A California consumer may not be discriminated against for exercising the consumer’s California privacy rights.
To make a request, please submit a request form or you may email us at email@example.com. In most cases, you will be required to provide your email address so that we can verify your request, and in some cases additional information may be required.
Please note that, when you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so. We will respond to your request within the 45-day time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event.
Under the CCPA, California consumers may use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that demonstrates authorization to submit a request for the California consumer. An authorized agent must follow the process described below to make a request, and we will also (a) require the authorized agent to verify the agent’s own identity and (b) confirm the agent’s authority with the California consumer about whom the request was made.
DO I HAVE ANY CHOICES REGARDING THE INFORMATION COLLECTED?
You may choose not to provide Personal Information to us by leaving the Site immediately.
LINKS TO OTHER WEBSITES
We welcome your comments regarding this Policy. If you have questions or concerns regarding this Policy, please contact us by regular mail at the following address:
For other jurisdictions, please direct your request to the address below.
Spectrum Brands, Inc.
Attention: Legal Department
3001 Deming Way
Middleton, WI 53562-1431