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Connected Appliance Privacy Policy

Last Updated / Effective Date: June 30, 2024

Sub-Zero Group, Inc. is committed to protecting the privacy of our customers. This Connected Appliance Privacy Policy (“Connected Privacy Policy”) provides information about how we collect, use, share, retain, and safeguard your Personal Information when you use our Connected Appliance Services (the “Services”) and our related Sub-Zero Group Owner’s App (the “Mobile App”) to utilize the interactive functions of your Sub-Zero Connected Appliance.

If you are using our website or our Sub-Zero Spec App, the Sub-Zero Privacy Policy applies instead of this Connected Privacy Policy.

IF YOU ARE A CALIFORNIA OR TEXAS RESIDENT, PLEASE SEE SECTION 10 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.

IF YOU ARE A CANADIAN RESIDENT, PLEASE SEE SECTION 11 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.

1. WHAT IS PERSONAL INFORMATION?

For purposes of this Connected Privacy Policy, “Personal Information” (sometimes referred to as personal data) means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information excludes publicly available information, aggregated or deidentified consumer information, or information which is otherwise excluded under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and their implementing regulations (“CCPA”) or the Texas Data Privacy and Security Act ("TDPSA"), as applicable.

2. PERSONAL INFORMATION WE COLLECT

We collect the following categories of Personal Information when you use the Services or the Mobile App. We have provided examples of the types of data collected in each category and information about how long we keep that data:

We collect the following categories of Personal Information:

Category of Data Examples Retention Period
Identifiers Name, email address, mailing address, postal code, phone number, IP address, unique personal identifiers, and device name. We retain Identifiers as long as we have a business relationship with you, which may extend through the life of our products.
Commercial Information Connected Appliance purchases (including replenishments), purchasing history (and related contact information), and invoices. We retain this information as long as we have a business relationship with you, which may extend through the life of our products.
Geolocation Information Imprecise location information such as your IP address and precise geolocation information concerning the location of your appliances.

Precise geolocation information concerning the location of your appliances.

Time Zone
For so long as required for our business purposes.
Sensory Information Voice recordings of your calls to customer service. We retain recorded call-center calls for 30 days.

3. THE PURPOSE FOR WHICH WE COLLECT THE INFORMATION & THE SOURCE

 

Information we collect directly from you or automatically when you use the Mobile App.

We collect Personal Information directly from you when you create an account, communicate with us or otherwise provide your information to us, as further described in the table below.

Purpose of Collection and Use Examples/Explanations Category
To Communicate with You To communicate with you about the features of your Connected Appliance and your Mobile App account (including service and warranty information);

To respond to your questions, requests or concerns;

To advise you of change to this Connected Privacy Policy;

To send notifications to you including notifications regarding your appliances;

To provide updates, text messages, push notifications, email alerts, including notifications of faults, product alerts, and end of cycle signals; and

To contact you if we receive a service notification for your registered Connected Appliance, or to issue other notices concerning the safety of your Connected Appliance.
Identifiers
Account Creation and Maintenance To enable you to create and manage your customer accounts and assist you with your accounts and your use of our Services and the Mobile App; and

To assist with resetting passwords and other needs for you to use the Services and the Mobile App.
Identifiers

Commercial Information
Customer Care and Support To provide you with customer care and support in connection with the purchase, delivery, installation, maintenance, service or repair of your Connected Appliance;

To facilitate warranty registration; and

To improve customer satisfaction.
Identifiers

Commercial Information
Business Purposes To improve our Connected Appliances, the Services and the Mobile App;

To engage in product research and development; and

To engage in business transactions.
Identifiers

Commercial Information
Marketing and Advertising To send you newsletters and other electronic correspondence notifying you of new Connected Appliance products, services and promotions; and

To market to you and to engage in advertising.
Identifiers

Commercial Information
Mobile App and Services Management To troubleshoot problems;

To protect the security of the Mobile App;

To perform statistical and other analyses of the Services and the Mobile App; and

To customize the Services and the Mobile App to you and our users.
Identifiers

Commercial Information
For Compliance and Legal Purposes To protect our legal rights or interests, or those of third parties;

To bring a legal action when necessary to protect legal rights;

To respond to California privacy rights requests;

To respond to other legal requests; and

To enforce violations of our Terms of Use.
Identifiers

Commercial Information
Identifying Your Region We may use geolocation information from the device you use to access the Mobile App to set the time-zone on your Connected Appliance. Geolocation Information

Information we collect from third-party sources and your Connected Appliance

We may obtain data from various third-party companies and public sources. We may combine that data with Personal Information or other data we collect.

Additionally, your Connected Appliance is equipped with electronic sensors that permit a two way exchange of data between the Connected Appliance and our computer system. This collection occurs automatically via our computer system, on a continuing basis. We collect and store the electronic data we receive from your Connected Appliance or from the electronic devices (such as cell phones, computers and tablets) you use to access the Services or the Mobile App ("Connected Data"). Some Connected Data may be considered Personal Information under certain laws.

Purpose and Use Examples Category of Information
Connecting Third Party Devices If you decide to connect your Connected Appliance to a third-party device or product to utilize that functionality of your Connected Appliance ("Third-Party Device"), we may receive Personal Information and Connected Data from that provider. Examples of such third-party Devices include without limitation any type of smart home hub device, specifically an Alexa-enabled device (e.g., Amazon Echo), Google Home device, or a Nest security system. Identifiers

4. SHARING PERSONAL INFORMATION

We disclose or share Personal Information with third parties for the following purposes:

With Whom We Share Personal Information Purpose Category of Information
Subsidiaries, Affiliates, Distributors, and Dealers We may disclose or share your Personal Information for our Business Purposes, including to facilitate a purchase and to service your products. Identifiers

Commercial Information
Third Party Device Providers If you decide to connect your Connected Appliance to a Third-Party Device, we may share information with them to facilitate that connection. Please review the Third-Party Device provider’s privacy policy to learn more about their privacy practices. Identifiers
Government Officials and Law Enforcement To comply with legal requirements, as ordered by a court or if we believe in good faith that the law requires it; and

To identify, contact, or bring a legal action against someone who may cause or be causing harm to you, us, our employees or other third parties, including anyone interfering with your appliances or our information technology systems.
Identifiers

Commercial Information
Service Providers We may share your Personal Information with the following types of service providers, in accordance with contractual provisions that require them to protect your Personal Information, as follows:

Customer Service: To sell, install, deliver, maintain, and service your Connected Appliances.

Mobile App Management: To operate and manage the Mobile App; to improve Mobile App content and functionality; and to support or provide the security of Services and the Mobile App.

Hosting: To host the Mobile App.

IT Services: To provide IT and software development services.

Marketing and Communications: To provide email services on our behalf; respond to your questions or comments on our behalf.

Other: We also share with service providers as indicated at the time and point of collection.
Identifiers

Commercial Information
Professional Advisors We may share your Personal Information to receive advice from our professional advisors, such as our attorneys, accountants, financial advisors, marketing consultants, and business advisors, in their capacity as advisors to us. Identifiers

Commercial Information
Parties to Business Transactions We may share your Personal Information in connection with a contemplated or completed business transaction such as a merger, acquisition, sale of all or substantially all of our assets or equity to a successor, subsequent owner or operator, a dissolution, bankruptcy, liquidation, or other similar business transaction where Personal Information may be shared, sold, or transferred to that third party, including during the due diligence process. Identifiers

Commercial Information

5. USE AND DISCLOSURE OF DE-IDENTIFIED OR AGGREGATED INFORMATION

 

We may de-identify or aggregate your Personal Information so it can no longer be used to identify you. Once we do this, the information is no longer considered Personal Information and we can use it for any lawful purpose. We will not attempt to reverse this process or attempt to re-identify you based on the de-identified or anonymized information.

 

6. YOUR CHOICES

We recognize that you may want to limit how your Personal Information is used and shared. We currently offer the following choices and options:

  • Opt-out of Marketing Communications. We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at [email protected] with "unsubscribe" in the subject line. To opt-out of other communications (e.g., postal marketing and telemarketing), please contact us as set forth in the "Contact Us" section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.
  • Mobile Location Choices. If you use our App, you may decline to provide location information through your mobile device settings or any prompt requesting location information.
  • Global Privacy Control. You may opt out of the sale or sharing of your Personal Information by broadcasting the Global Privacy Control (“GPC”) (on the browser and/or browser extension that supports the GCP signal). To download and use a browser supporting the GPC signal, click here. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Additionally, if you are a California or Texas resident, you may opt out by filling out the form here.

7. PROTECTION OF CHILDREN’S PERSONAL INFORMATION

We do not publish content that is targeted to children. We do not intend for children under the age of 16 to use the Services or the Mobile App. We do not knowingly collect, maintain, or disclose a child's Personal Information. If you are under 16, you should not send any Personal Information about yourself to us.

If you are a parent or guardian who has discovered that your child under the age of 16 has submitted his or her Personal Information without your permission or consent, we will make reasonable efforts to remove the information from our database, at your written request. To request the removal of your child's information, please send an email to [email protected] and be sure to include the same information that your child submitted. For clarity, we do not sell the Personal Information of anyone under the age of 16 years old without affirmative authorization.

8. CHANGES TO POLICY

WE MAY, AT ANY TIME, REVISE THIS CONNECTED PRIVACY POLICY BY UPDATING THIS POSTING. IF WE MAKE A MATERIAL CHANGE TO THIS CONNECTED PRIVACY POLICY, WE WILL POST A NOTICE ON THE TOP OF THIS POLICY, ON OUR SITE OR NOTIFY YOU BY ANOTHER METHOD THAT WE HAVE MADE CHANGES TO THIS CONNECTED PRIVACY POLICY. ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING. 

9. THIRD PARTY LINKS

We are not responsible for any content offered on any third-party websites, devices or applications. Links to third-party websites or applications are provided for your convenience only. This Connected Privacy Policy will not apply to any Personal Information that you provide to, or that is collected by, any third-party website operator, third-party product or service provider, or Third-Party Device Provider. Other third-party services or applications, like your wireless data plan or phone provider, have their own privacy statements. Those third-party privacy policies have separate terms and should be read separately from this Connected Privacy Policy.

10. TERMS APPLICABLE TO RESIDENTS OF CALIFORNIA AND TEXAS

This Section 10 provides additional terms that apply to residents of California and Texas. In the event of a conflict between this Section 10 and the remainder of this Connected Privacy Policy, this Section shall take precedence for California and Texas residents. Capitalized terms in this Section that are not defined elsewhere in this Connected Privacy Policy have the definitions set forth in the CCPA or TDPSA, as applicable.

ADDITIONAL INFORMATION ABOUT OUR PROCESSING 

Categories of Personal Information We Have Collected. During the past 12 months, we have collected the categories of Personal Information listed above in the “Personal Information We Collect” Section.

Categories of Personal Information Disclosed for a Business Purpose. During the past 12 months, we have disclosed the following categories of Personal Information for a Business Purpose: Identifiers and Commercial Information.

Categories of Personal Information Sold or Shared. In the last 12 months we have not Sold or Shared Personal Information collected through the Mobile App.

We Do Not Use or Disclose Sensitive Information. We do not use or disclose sensitive information, as defined in the CCPA.

 

YOUR CALIFORNIA AND TEXAS PRIVACY RIGHTS

California and Texas Residents have additional privacy rights, subject to certain exceptions. If you live in California or Texas, you may exercise those rights listed below.

Right to Know. If you are a California resident, you have a right to request that we provide you with certain information about how we have used your Personal Information over the last 12 months.

Once we receive your request and confirm your identity, we will provide you with the following:

  • The categories of Personal Information we collected from or about you;
  • The categories of sources from which the Personal Information was collected;
  • The Business or Commercial Purpose for collecting, Sharing, or Selling your Personal Information;
  • The categories of Third Parties to which we have disclosed your Personal Information;
  • The specific pieces of Personal Information we have collected about you;
  • The categories of Personal Information that we Sold, Shared, or disclosed for a Business Purpose; and
  • The categories of Third Parties to which that information was disclosed for a Business Purpose.

If you are a Texas resident, once we have verified your request, we will confirm whether we are processing your Personal Information and allow you to access that Personal Information.

Right to Request Deletion. You have a right to request that we delete Personal Information we collected from or about you. We will comply with such requests and direct our service providers or third parties to do the same, subject to certain exceptions permitted by applicable law.

Right to Correct. You have the right to correct inaccurate Personal Information that we collect about you. If we receive a verifiable request, we will consider it, taking into account the nature of the Personal Information and the purposes for which we process the Personal Information. We may deny your request if we are unable to verify your identity or if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances. We may request that you provide us with documentation that is relevant to your request.

Please note, we may choose to delete the contested Personal Information as an alternative to correcting it, if doing so would not negatively impact you or with your consent.

Right to Data Portability. You have the right to request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.

Non-Discrimination. You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA or TDPSA. 

If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.

How to Exercise Your California or Texas Privacy Rights. To exercise your rights, you may contact us at any of the following:

By Mail:

Sub-Zero Group, Inc.
Attn: General Counsel
4717 Hammersley Rd.
Madison, WI 53711

By Phone: +1-800-222-7820>

Visit our Website: https://www.subzero-wolf.com/assistance
Email us at: [email protected]

Who May Exercise Your Rights. You, or a person that you authorize to act on your behalf, may exercise your data privacy rights. See the section titled “Using an Authorized Agent” for more information.

Parents and Guardians. If you are a parent or legal guardian, you may make a request on behalf of your child.

Verifiable Consumer Request. You must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

If you submit a request to exercise your privacy rights, we will confirm that we have received it. We will use the information we already have about you to verify your identity. However, depending on the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc., we may ask you to provide additional information, including Personal Information.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will deny your request and let you know why.

When We Will Respond To Your Request. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Using an Authorized Agent. You may submit a request to exercise your rights through an authorized agent – another person you authorize to act on your behalf.

Additionally, California requires that, if you submit a rights request through an agent, you must (a) provide signed, written permission that authorizes the agent to submit requests on your behalf and (b) verify your identity directly with us or (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, if you are a California resident, you are required to verify your identity and the identity of your authorized agent.

We may deny a request from an authorized agent if we do not have proof that you have authorized them to to act on your behalf.

Right to Appeal for Texas Residents

If you are a Texas resident and we deny your rights request, you have the right to ask us to reconsider. You must submit your appeal within 60 days of your receipt of our denial:

By Mail:
Sub-Zero Group, Inc.
Attn: General Counsel
4717 Hammersley Rd.
Madison, WI 53711

By Phone: +1-800-222-7820

Through Product Support: https://www.subzero-wolf.com/assistance

By Email: [email protected]

We will acknowledge your appeal when we receive it. Within 60 days, we will inform you in writing whether we have reconsidered your request or declined to do so. We will also provide an explanation of our decision.

CALIFORNIA SHINE THE LIGHT.

Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us as set forth at the end of this Connected Privacy Policy to receive this information.

11. TERMS APPLICABLE TO CANADIAN RESIDENTS

Your Canadian Privacy Rights. Under Canadian privacy laws you have certain rights to access and correct Personal Information, subject to identity verification requirements and certain exceptions.

Right to Access. You have the right to confirm that we hold Personal Information about you, receive an explanation about how we use your Personal Information, and obtain access to your Personal Information.

Right to Rectification. You have a right to examine and challenge the accuracy and completeness of your Personal Information, and have your Personal Information amended where appropriate.

Right to Withdraw Your Consent. You have the right to withdraw your consent to processing your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice. If your withdrawal of consent implicates the quality of our services to you, we will notify you.

Right to Complain to a Data Protection Authority. You also have the right to lodge a complaint regarding the processing of your Personal Information with the applicable data protection authority. Please contact your local data protection authority for more information.

How to Exercise Your Rights. To exercise your rights described in this Section, you may submit your request to us by contacting us using the contact information listed below. 

DATA TRANSFERS AND CONSENT TO PROCESSING OUTSIDE OF CANADA OR QUEBEC

We are based in the United States.  We may transfer your Personal Information to the United States in connection with the operation of our business.

To assist us in meeting our operational and legal obligations, we may also transfer or make your Personal Information accessible to one of our service providers located either in Canada (both inside and outside Quebec) or throughout the world.

When we transfer your Personal Information outside of Canada, your Personal Information may be available to government officials in the United States or other countries. These countries have privacy laws that differ from Canadian privacy laws.

ADDITIONAL TERMS APPLICABLE TO QUEBEC RESIDENTS ONLY

If you are resident of Quebec, Quebec law provides you with additional rights regarding the use of your Personal Information, subject to identity verification requirements and certain exceptions.

Right to Restriction of Processing. You have a right to direct us to cease disseminating your Personal Information or to de-index any hyperlink attached to your name that provides access to the information by a technological means, if the dissemination of the information contravenes the law or a court order.

Right to Request Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

Right to Portability. You may request copies of the Personal Information you have provided to us. Where possible, we will deliver the copy of your Personal Information to you using a structured, commonly used, and machine-readable format. Alternatively, you may request that we send your Personal Information to another business.

How to Exercise Your Rights. To exercise your rights described in this Section, you may submit your request to us by contacting us using the information below.

Translations.
This Connected Privacy Policy may be provided in several languages. In the event of conflict or inconsistency, the English language version of this Connected Privacy Policy controls, unless otherwise required by applicable law. En cas de conflit ou d'incohérence, la version anglaise de cette politique de confidentialité contrôle, sauf si la loi applicable l'exige.

12. CONTACT US

If you have any questions or comments about this Connected Privacy Policy, please contact us at:

Sub-Zero Group, Inc.
Attn: General Counsel
4717 Hammersley Rd.
Madison, WI 53711
+1-800-222-7820
https://www.subzero-wolf.com/assistance
[email protected]

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