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Culligan California Privacy Notice

Effective Date: January 1, 2020

The California Consumer Privacy Act (the “CCPA”), a new privacy law that provides California consumers certain rights regarding their personal information (“PI”) became effective on January 1, 2020. However, as of that date the California Attorney General had not completed the rule making process to establish the regulations for covered businesses to implement the law. Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the development of the law and our understanding of how it relates to our data practices. In the meantime, this Notice outlines the PI we collect subject to the CCPA and our purposes for that collection.

In addition, if you are a California consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold” (including your right to obtain copies of specific pieces of PI and/or information about categories of PI practices), your “right to request deletion of personal information,” or your “right to opt-out of the sale of personal information,” (“CCPA Rights”) you may contact us at CAPrivacyRequest@culligan.com.  We will respond to your request as soon as we have guidance on how to properly verify your identity and the means to respond; however, note that CCPA Rights do not apply to PI collected from (a) job applicants, current and former employees or independent contractors (“HR Data Subjects”), or (b) representatives of another business in connection with business communications or transactions (“B-to-B Data Subjects”). HR Data Subjects who are also California residents may learn more about our data collection practices by contacting their human resources department.

We collect PI from California consumers (but excluding B-to-B Data Subjects, who are not entitled to this notice) for the following purposes:

Category of PI Examples Purposes
  1. Identifiers
This may include but is not limited to: a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This may include but is not limited to: to enhance our users’ online experience and for on and/or offline marketing.
  1. Personal Records
This may include but is not limited to: telephone number, credit card number, debit card number, or any other financial information. This may include but is not limited to: for the purposes of contacting you for scheduling and/or completing transactions and to pay for our products and/or services.
  1. Commercial Information
This may include but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This may include but is not limited to: for customer service and marketing purposes.
  1. Internet Usage Information
This may include but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement This may include but is not limited to: to ensure network and information security and, if necessary, to detect and prevent fraud or inappropriate usage.
  1. Geolocaiton Data
This may include but is not limited to: precise or approximate physical location. This may include but is not limited to: to more accurately provide local water quality information and/or for other marketing purposes.
  1. Sensory Data
This may include but is not limited to: audio recordings of customer care calls, or similar information. This may include but is not limited to: to monitor and improve the overall customer experience.
  1. Inferences from PI Collected
This may include but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, predispositions, behavior, and attitudes. This may include but is not limited to: to enhance our users’ online experiences and for on and/or offline marketing.

 

We will revise this California Privacy Notice from time-to-time as the law becomes clearer and we are able to provide you with better information on your CCPA rights and how to exercise them.

Although there is not yet a consensus, we currently do not believe that the collection of data by third party cookies and related technologies associated with our online services result in a sale of your PI by us. However, please visit our Privacy Policy to learn how you can exercise certain choices regarding these activities.

Third Party Marketing and Your California Privacy Rights: We provide California residents with the option to opt-in or opt-out to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than any Culligan dealers that are authorized by Culligan to sell Culligan services or products, for such third parties own direct marketing purposes. California residents may exercise that opt-out, and/or request information about our compliance with the Shine the Light law, and obtain disclosure of third parties we have shared information in accordance with the law for their direct marketing purposes absent your choice and the categories of information shared, by emailing us at  CAPrivacyRequest@culligan.com  or by sending a letter to Culligan at 9399 W. Higgins Rd., Ste 1100, Rosemont, IL 60018, USA, (Attention: Privacy Officer). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mail address.

For additional information on our data practices, including cookies on our web site(s), see our Privacy Policy.