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, business contacts, 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.
NOTICE OF COLLECTION
"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 maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify consumer or customer information, process payments, perform analytics, storing data, for advertising and marketing, internal research, to verify and maintain the quality or safety of products and services, for auditing the use of the Services or other products or services, 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, enter information into a text box on a Site (even if you navigate away without submitting) 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, remind you to complete a purchase, 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 including through calls, text messages, emails, and push notifications, and facilitate targeted 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. We receive your email address and password when you submit them to log into certain Sites, and they may be considered sensitive Personal Information under applicable privacy laws. We do not draw inferences from information we receive to facilitate logins.
- 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, targeted advertising, and determine eligibility for contests.
- Financial information. We may receive your payment card related information when you make payments to us, which may be considered sensitive Personal Information under applicable privacy laws. We use and share payment card information with our payment processor to process transactions requested by you, retain the information long enough to facilitate the transaction, and do not “sell” or “share” the information for third-party targeted advertising (as those terms may be defined by applicable privacy laws). We also receive information about completed purchases from our payment processor when you make a purchase. We do not draw inferences from payment card information we receive.
- 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. Except as otherwise stated 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 continue to provide your Personal Information to us by leaving the Site immediately. Please note that if you do not provide requested 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 of Personal Information 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.
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.
Sensitive Personal Information.
Other than as stated above, we generally do not collect or process sensitive Personal Information (e.g., racial or ethnic origin, religious beliefs, mental or physical health data, sex life or orientation, citizenship status, biometric data for the purpose of uniquely identifying an individual, personal information from a known child, account credentials, or information that allows access to financial accounts) about users through the Services.
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. Once de-identified, we will maintain the data in de-identified form and not attempt to re-identify it.
Retention of Personal Information
As a general matter, we keep information only for as long as necessary to fulfill the purposes for which it was collected, provide you with our products and services, resolve disputes and enforce agreements, and as stated in our retention policies or as permitted or required by law, such as to comply with recordkeeping and other legal obligations. There may also be residual information that will remain within our backup files, databases, and other records, which will not be removed or changed, except in accordance with retention policies.
Selling and Third-Party Targeted Advertising.
As stated more fully below, certain brands within Spectrum “sell” or “share” Personal Information for third-party targeted advertising as those terms are defined by applicable law. The Personal Information includes personal identifiers, personal characteristics, commercial transaction information, website and mobile application usage activity, and inferences we generate about you based on the information we have received. You may opt out of the “sale” of Personal Information and the “sharing” of Personal Information for third-party targeted advertising by going to the Cookie Settings and turning off “Targeting Cookies” and “Performance Cookies”, and may opt out of the “sale” of Personal Information by emailing firstname.lastname@example.org . The Sites also respond to universal opt-out and privacy control signals as explained here
. However, the Sites do not respond to Do Not Track signals.
Read our entire Policy here.
NOTICE OF SHARING
We share the categories of Personal Information we receive (listed above) for our business and commercial purposes (including to maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify consumer or customer information, process payments, perform analytics, storing data, advertising and marketing, internal research, to verify and maintain the quality or safety of products and services, auditing the use of the Services or other products or services, defend and protect us and others from harm or legal claims, and as required by applicable law) and as more specifically described below.
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.
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.
Marketing, data, and other companies.
Certain brands within Spectrum share Personal Information with merchant partners and marketing, data, analytics, social media, and advertising companies (like advertising agencies, marketing cooperatives, analytics providers, data brokers, social networks, providers of sponsored content, and others) that may use the information for our, their, and others’ marketing and advertising purposes. This may constitute “selling” Personal Information, as defined by applicable state law. Certain brands within Spectrum may also permit third-party partners and advertisers to track visitors to the Sites or the recipients of Spectrum emails and the activities of those visitors and recipients over time, and they may track those visitors and recipients across other websites and online services over time, including for targeted advertising and joint marketing purposes. This may constitute the “sharing” of your Personal Information for third-party targeted advertising as defined by applicable state law. The Personal Information used and shared for these purposes includes personal identifiers, personal characteristics, commercial transaction information, website and mobile application usage activity, and inferences we generate about you based on the information we have received. Please visit the Cookie Settings to request that we limit this selling or sharing for targeted advertising. The Sites also respond to universal opt-out and privacy control signals as explained here
. However, the Sites do not respond to Do Not Track signals.
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.
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.
Government agencies, legal, and similar disclosures.
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.
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 know about our practices with respect to your Personal Information and to review, correct, receive, receive in a portable manner, and delete Personal Information we have about you, or to consent or withdraw consent to certain uses or sharing of Personal Information (e.g., a right to opt-out of the “sale” of Personal Information or “sharing” of Personal Information for targeted advertising, as described above). You may also have the right to not be discriminated against for exercising your privacy rights.
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 and your location. 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.
You may have the right to use an authorized agent to make privacy rights requests. We may require the authorized agent to provide us with proof of your written permission (for example, an executed written consent form) that demonstrates authorization to submit a request for you. 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 individual about whom the request was made. Note that an authorized agent may not be able to fully complete certain opt-out requests on your behalf, because they impact your browser, mobile application, or device.
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.
Responding to Requests.
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.
Contact us at firstname.lastname@example.org to appeal our decision to deny your request. Please include in your appeal request all information about your original request and our denial response to you. We will review and respond to your appeal as required by applicable law.
Do Not Sell and Opting Out of Targeted Advertising.
As stated above, certain brands within Spectrum “sell” Personal Information or “share” Personal Information for third-party targeted advertising as defined by applicable state law. Please visit the Cookie Settings to request that we limit this selling or sharing for targeted advertising, or 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.
The Sites also respond to universal opt-out and privacy control signals as described here.
Opting Out of Marketing Emails.
As described above, our brands may use the Personal Information collected from you to offer you products and services that may be of interest to you or to remind you about products you have in the past expressed interest in. If you would like to opt out of receiving future marketing materials by email from those brands, you may indicate this preference by following the unsubscribe instructions in the marketing emails. Even if you opt out of marketing emails from us, we will continue to send you transactional and account-related information.
Opting Out of Marketing Text Messages.
With your consent, we may use your Personal Information to send text messages (including SMS and MMS messages) using an autodialer and push notifications from us or on our behalf at the telephone number you provided even if that number is on a National or State Do Not Call List. These messages and push notifications may be for marketing purposes. IF YOU WISH TO OPT OUT OF SMS AND MMS TEXTS FROM US, YOU MAY REPLY “STOP” FROM THE MOBILE DEVICE RECEIVING THE MESSAGES. YOU MAY TURN OFF PUSH NOTIFICATIONS IN THE MOBILE APPLICATION OR YOUR DEVICE SETTINGS.
CALIFORNIA NOTICE AND PRIVACY RIGHTS
We have disclosed in the last 12 months the categories of Personal Information listed above in this Policy for our business and commercial purposes (including to maintain or service customers, provide customer service, process or fulfill orders and transactions, verify consumer or customer information, process payments, perform analytics, storing data, advertising and marketing, internal research, to verify and maintain the quality or safety of products and services, auditing the use of the Services or other products or services, defend and protect us and others from harm or legal claims, and as required by applicable law). We do not use or disclose sensitive Personal Information for purposes other than those specified in section 7027, subsection (m).
California residents have the privacy rights listed above in this Policy. In addition to the privacy rights listed above, California residents have a right to know the categories of personal information collected, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about them.
California residents may make a privacy request using the
, emailing us at firstname.lastname@example.org
As stated above, certain brands within Spectrum “sell” or “share” Personal Information as those terms are defined by California law. We will not knowingly sell the Personal Information of individuals we know are under 16 years old without prior consent. California residents may opt out of the “sale” or “sharing” of Personal Information for third-party targeted advertising (as those terms are defined by California law) by visiting the Cookie Settings. The Sites also respond to universal opt-out and privacy control signals as explained here
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. To obtain this information from us, please send an email message to
or mail us at the address below with “Request for California Shine the Light Information” on the subject line and in the body of your message. If you are a California resident, we will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Notice of Financial Incentive
Spectrum may provide certain offers, discounts, or other benefits only to consumers who voluntarily enroll in certain subscription programs: (1) email promotions from Spectrum and certain brands by submitting their email address where prompted on the Sites, and they will receive a coupon for a percentage off a consumer’s purchase, (2) text alerts from Spectrum and certain brands by submitting their mobile numbers where prompted on the Sites, and will receive a coupon code to use towards a future purchase, and (3) sweepstakes or contests where a specified offer, prize or discount may be awarded to one or more winner(s) who register. If you enroll or register, we use the name, email address and telephone number to identify you as having a subscription and providing you with personalized messaging and deals. Certain subscriptions, sweepstakes, and contests may have additional terms and conditions, which may change from time to time.
You may opt-out of a subscription, sweepstakes, or contest at any time by following the instructions for opting out of marketing emails and text messages provided above. You may also submit a request using the
or the email email@example.com
. If you opt-out of a subscription, sweepstakes, or content, you will no longer receive the discounts, offers, and other benefits provided to individuals who are participating in the subscription, sweepstakes, or content.
Spectrum does not generally assign monetary value to consumers’ personal information, and discounts, sweepstakes, and contests associated with the Spectrum’s subscription programs changes continually. Spectrum values the information collected and used under each subscription program as being equal to the value of the discounts or other financial incentives provided in each such program, based upon a practical and good-faith effort to assess, on an aggregate basis for all collected information: (a) the type of information collected in each program (e.g., email address), (b) the use of such information by Spectrum or its brands in connection with its marketing activities, (c) the range of discounts provided (which can depend on each consumer’s purchases under such offers), (d) the volume of individuals enrolled in the programs, (e) the products for which the benefits (such as a discount) can apply, and (f) the expenses associated with the subscription programs, which vary depending on the level of engagement and the use of the discounts and offers. These variable factors continue to change over time.
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:
Spectrum Brands, Inc.
Attention: Legal Department
3001 Deming Way
Middleton, WI 53562-1431