Last Updated / Effective Date: January 11, 2024
IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 12 BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.
IF YOU ARE A CANADIAN RESIDENT, PLEASE SEE SECTION 13 BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.
1. WHAT IS PERSONAL INFORMATION?
For purposes of this Policy, "Personal Information" 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 from the under the California Consumer Privacy Act of 2018, as amended and its regulations (“CCPA”).
2. PERSONAL INFORMATION WE COLLECT
We collect the following categories of Personal Information. We have provided examples of the types of data collected in each category and information about how long we keep that data:
|Category of Data
|Name, email address, mailing address, postal code, phone number, IP address, unique personal identifiers, device name, and project type.
In connection with your employment at Sub-Zero, we may collect social security numbers, driver’s license, or passport numbers.
|We retain Identifiers as long as we have a business relationship with you, which may extend through the life of our products.
When you provide us with Identifiers related to your job application or your employment, we keep that information as required by applicable law.
|Name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
|We retain this information as long as we have a business relationship with you, which may extend through the life of our products.
|Gender and ethnic origin (if you choose to provide that information on your job application), eligibility to work in the US, and disabilities (if you choose to disclose that in a job application or request accommodations).
|As required by law.
|Records of products or services you purchased or received, or considered, other purchasing history, invoices, and warranty records.
|We retain this information for as long as you maintain an account with us; while we keep a business relationship with you; for the life of the product; and for as long as is required for any other business or legal purpose.
|Browsing history, performance / telemetry statistics, errors encountered, device type, browser preferences and version, showroom location preference, visited URL, videos viewed, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
|As long as is needed for our business purposes.
|Imprecise location information such as your IP address.
|For so long as required for our Business Purposes.
|Audio, electronic, and visual information, including CCTV recordings.
|We retain recorded call-center calls for 30 days and video recordings for approximately 3 months.
|Employment history, resume, references, contact information, emergency contact information, professional certifications, associations, disciplines, pay requirements, licenses and certifications held, skills, and experience.
|As required by law.
|Educational background, graduation date, degrees, trade association membership, and trade certifications.
|As required by law.
|Information that could be used to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
|As long as is needed for business and marketing purposes.
|Sensitive Personal Information
|We do not collect Sensitive Personal Information as defined under the CCPA for marketing or advertising purposes.
3. SOURCE OF THE INFORMATION WE COLLECT & THE PURPOSE FOR WHICH WE COLLECT IT
Information we collect directly from you or automatically when you visit our Site or use our App.
We collect Personal Information directly from you when you create an account, purchase and register a product, communicate with us or otherwise provide your information to us, as further described in the table below.
|Purpose of Collection and Use
|To Communicate with You
|To answer your questions, comments, or concerns;
To respond to questions about products or services we offer;
To arrange and make service calls;
To send you information about your products such as service and warranty information or recall information;
To notify you of new products, services, programs, and Site features;
To comply with privacy rights requests; and
As you otherwise request or consent.
|Account Creation and Maintenance
|To assist you in creating a My Sub-Zero account and in maintaining that account; and
To register your products through the Site.
|Purchase, Delivery, Customer Service, and Warranties
|To place and fulfil your orders;
To take and process payments;
To keep a record of your purchases;
To deliver your products and provide services;
To provide customer service;
To respond to your warranty claims and send you warranty information; and
To process your returns and exchanges.
|To facilitate transactions;
To inform our business strategies;
To engage in product research and development;
To operate the Site and the App;
To manage profiles;
To monitor and improve our products and services;
To seek business, financial or legal advice;
To engage in business transactions; and
To administer your employment and benefits.
|To perform analytics on your use of the Site; and
To understand the Site’s demographics and user preferences.
|Marketing and Advertising
|To send you promotions;
To market to you and to engage in advertising;
To serve you targeted advertising;
For sweepstakes or contests; and
To send you e-mail promotions.
|To troubleshoot problems with the Site;
To improve the content and functionality of the Site;
To protect the security of our Site;
To conduct statistical and other analyses of the Site; and
To customize the Site to you and our other users.
|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 address any U.S. DMCA claims or counterclaims;
To respond to California privacy rights requests; and
To respond to other legal requests.
|Processing Job Applications
|To accept job applications and to evaluate your qualifications for employment.
Information we collect from third-party sources.
|Purpose of Collection and Use
|We use a third-party PCI-compliant payment processor ("Payment Processor") to facilitate online purchases. When you make an online payment using a Payment Processor, we receive your contact information and purchase information but do not receive your credit card, debit card or other financial information.
|If you submit a job application or related materials online to work with us, you will be redirected from our Site to a website operated by our service provider UKG.
We receive your Personal Information from UKG when you create an account and submit your application.
|We use an event management tool that allows individuals to register for our events. If you sign up for an event, we will receive that information from that service provider.
|We may receive Personal Information from third parties or service providers, which help us supplement the Personal Information we collect in order to prioritize sales efforts and better understand our customers and potential customers.
Subsidiaries, Affiliates, Distributors, and Dealers
4. SHARING PERSONAL INFORMATION
We disclose or share Personal Information with third parties for the following purposes:
|With Whom We Share Personal Information
|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.
|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.
|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 appliances.
Payment Processing: To provide payment processing services.
Site: To operate and manage our Site and App; to improve Site and App content and functionality; and to support or provide the security of the Site and App.
IT Services: To provide IT services.
Employment: In connection with administration of your employment and benefits.
Analytics: To perform data analysis and statistical analysis.
Job Applications: To manage employment applications.
Videos: The Site contains videos and embedded content, including visible content and/or feeds scripts embedded in the Site's code. Our service providers may collect data about how you interact with such content, including which videos you watch.
Other: We also share with service providers as indicated at the time and point of collection
|Marketing and Advertising Partners
|We work with certain advertising partners and utilize targeted advertising. In doing so, we may share your Personal Information to facilitate targeted advertising or other marketing services. This may be considered “selling” or “sharing” of your Personal Information under California law.
|Other Third Parties
|We may share your Personal Information to facilitate your showroom visits, to help run sweepstakes and contests, and to provide public relations services.
|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.
|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.
5. USE OF DE-IDENTIFIED OR AGGREGATED INFORMATION
We may collect, use, share, transfer, and otherwise process Personal Information that we then de-identify, aggregate, or both so that your Personal Information is no longer identifiable. Once Personal Information has been de-identified and aggregated, it is no longer considered Personal Information under applicable laws, and we may use this information for any lawful purpose.
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:
- Update your Personal Information. You may update your Personal Information by contacting us using the information in the “Contact Us” section below.
- Update your My Sub-Zero Account. You can access and update your name, email address, street address, and warranty information by logging into your My Sub-Zero Account on our Site.
- Opt Out of Targeted Marketing. If you wish to limit or opt out of third-party advertising, you can do one or more of the following:
- Change your Preferences. To change your preferences with respect to certain online ads and to obtain more information about ad networks and online behavioral advertising visit the National Advertising Initiative Consumer Opt Out page and the Digital Advertising Alliance’s Consumer Choice Tool. Please note that even if you opt-out of receiving interest-based advertising, you may still receive advertisements, but they will be more general in nature. In addition, the electronic device you use to visit our Site may offer relevant privacy settings; please see the device settings for details.
- For California Residents. If you are a California resident, you may opt out of the sale or sharing of your Personal Information by broadcasting an opt-out preference signal, such as the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser 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, you may fill out the form here.
- Opt Out of Marketing Emails. You can opt out of marketing or advertising emails by clicking on the unsubscribe button 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 prevent you from receiving 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.
We use commercially reasonable physical, technical, and organizational measures to help maintain the security of your Personal Information and protect against unauthorized access or acquisition. If we experience a data security incident involving your Personal Information, we will notify you of the incident if required under applicable law.
8. PROTECTION OF CHILDREN'S PERSONAL INFORMATION
We do not publish content that is targeted to children. We do not intend to collect Personal Information from anyone under age 16 and will not knowingly collect, maintain, or disclose such 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 Personal Information to us without your permission or consent, we will make reasonable efforts to remove the information from our records, at your written request. To request the removal of your child's information, please send us an email at [email protected] and be sure to include the same information that your child submitted. For clarity, we do not knowingly sell or share the Personal Information of anyone under the age of 16 years old.
9. LINKS TO OTHER WEBSITES
Social Media. We are active on social media sites, including Facebook, YouTube, Instagram, Twitter, and LinkedIn. Anything you post on our social media sites is public information and will not be treated confidentially. We may post (or re-post) on the Site, or our social media pages, any comments or content that you post on our social media pages.
10. CHANGES TO POLICY
11. CONSENT TO PROCESSING IN THE UNITED STATES
If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions, such as in Canada and the European Union.
12. TERMS APPLICABLE TO CALIFORNIA RESIDENTS
YOUR CALIFORNIA PRIVACY RIGHTS
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, Protected Classifications, Commercial Information, Customer Records, Internet Activity, Geolocation Data, Sensory Information, Employment Information, Education Information and Inferences.
- Customer Records
- Commercial Information
- Internet Activity
We Do Not Use or Disclose Sensitive Information. We do not use or disclose sensitive information, as defined in the CCPA.
Right to Know: You have a right to request that we disclose certain information about you and our collection and use of your Personal Information over the last 12 months.
Once we receive your request and confirm your identity, we will disclose to you as required under the CCPA:
- 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.
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.Right to Limit the Use of Sensitive Personal Information. CCPA provides consumers with the right to request that we limit the use of your Sensitive Personal Information, as defined in that statute. We do not use any Sensitive Personal Information to make inferences about you.
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 Privacy Rights. To exercise your rights under the CCPA, you may contact us at any of the following:
Sub-Zero Group, Inc.
Attn: General Counsel
4717 Hammersley Rd.
Madison, WI 53711
By Phone: +1-800-222-7820
Who May Exercise Your Rights. If you are a California resident, only you or a person that you authorize to act on your behalf may make a request related to your Personal Information. See the section titled “Using an Authorized Agent” for more information. A parent or legal guardian may make a request on behalf of their 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.
When we receive your request to exercise your rights under the CCPA, we will: (a) acknowledge receipt of your request; (b) try to match the information that you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (d) consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc. 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 decline to comply with 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 have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If you choose to use an authorized 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, you are required to verify the identity of both you and the authorized agent.
We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Notice of Right to Opt Out of Sale/Sharing
You have the right to opt out if we sell or share Personal Information with a third party as defined in the CCPA. To make a request, visit our Do Not Sell or Share My Personal Information page.
CALIFORNIA SHINE THE LIGHT
13. TERMS APPLICABLE TO CANADIAN RESIDENTS
Your Canadian Privacy Rights. Under Canadian privacy laws you have certain rights to access and correct Personal Information, including the right:
- To be informed of the existence, use and disclosures of your Personal Information;
- To receive an account of the uses that have been made of your Personal Information by us and any third parties to whom it has been disclosed;
- To be given access to your Personal Information; and
- To challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.
Please contact us using the information provided below in Section 14 to exercise your rights under Canadian privacy laws or for any other privacy-related complaints or inquiries. We may require that you provide information verifying your identity before we provide this requested information to you.
Legal Disclosures and Lawful Requests. We and our Canadian, U.S., and other foreign affiliates and relevant service providers may disclose your Personal Information in response to a search warrant, other legally valid inquiry or order, or as may otherwise be required or permitted by applicable law, which may include lawful access by U.S. or foreign courts, law enforcement, or other government authorities. We may also disclose your Personal Information to another organization in order to enforce our rights arising from any contracts we have entered into, including to investigate a breach of contract or violation or law, as well as to detect, suppress, or prevent fraud. Finally, we may disclose your Personal Information as necessary to establish, exercise, or defend against legal claims and to investigate or prevent actual or suspected loss or harm to people or property.
14. CONTACT US