Effective Date: December 2, 2015.
The Online Services are not directed, nor do we knowingly retain any personal information about any individual under 13 years of age. To the extent permitted by applicable laws, we will securely delete such information from our systems upon being requested to do so by a parent or legal guardian. To the extent permitted by law, we may, however, retain personal information about an individual that is less than13 years of age where: (i) such individual has purchased a product through the Online Services and cancels such purchase and whereby we must retrieve the underlying product sold to such individual; (ii) such personal information is relevant to litigation or potential litigation; (iii) such individual has undertaken any wrongful conduct or conduct that is otherwise actionable in regards to the exercise by Schluter or its affiliates of any remedy available to them; and/or (iv) such retention is reasonable and otherwise permitted under applicable laws.
1. Why is information collected?
The following is a summary of some of the reasons why information is collected in regards to your access of the Online Services:
- to make use of certain features of the Website or to provide you with the products, services, or information you have requested.
- to help us improve the Website by better understanding how the Website is being accessed and used by you and other end users.
- to help us assess products sold through the Website and determine which products should be offered through the Website and how such products may be improved.
- to communicate with you about the Online Services, respond to your inquiries, or to send you promotional offers and materials with respect to the Website, our products and/or those of our affiliates.
- personalize the content of the Online Services, such as by providing interactive content or content based on your interests.
- deliver targeted advertisements that are based on your online activities on the Online Services and other third-party websites (for example, if you view a product on our Online Services, you may receive an online advertisement for our products on the Online Services or on other online platforms you may visit).
- generating and analyzing statistics about your use of the Online Services.
We may combine or aggregate any of the information we collect through the Online Services, offline, or elsewhere for any purpose.
2. What information is collected and for what purpose is it being collected?
Use of the Online Services
The following information may be collected when you access and use of the Online Services or certain sections or features of the Online Services:
- You may be required to provide your name, e-mail address, mailing address and/or phone number when you request product information or contact us in regards to warranty claims for Schluter products;
- You may be required to provide your name, e-mail address, mailing address and/or telephone number when you create a user account for the Website; you may also have the option of providing additional information about yourself such as your future intentions in terms of product purchases or renovation projects, your age, marital status and other demographic information. We may suggest and recommend Schluter products to you based on your user profile generated by your registration information;
- The Website allows registered users to create lists of renovation projects that they are contemplating (each, a " Project Description"). Such Website feature includes certain pre-determined fields that can be populated by an end user as well as an open form field that allows an end user to provide a narrative of the project, requirements and other details deemed useful by an end user. Likewise, the Website allows registered users who access product detail pages for Schluter products on the Website to create an association between such Schluter products and a Project Description. Information provided in Project Descriptions will be used to generate a list of recommended project templates that will be presented to you can be used by you to identify project goals and requirements. Likewise, information provided in Project Descriptions will be used to generate a list of "Related Products", namely a list of Schluter products that fall within the project requirements or that otherwise have some relevance to the underlying project. Project Descriptions associated with a particular user will be grouped in a list (a "Project List "). An end user can choose to publish a Project Description and/or a Project List for Schluter dealers through the Website or generally, through social media platforms. You acknowledge and understand that if you use such feature and include information in a Project Description or a Project List and later decide to publish such Project Description or Project List, such information will become accessible to Schluter dealers and to those persons that have access to posts of such nature through your social media account.
- The Website allows you to register for workshops. If you choose to do so, you will be asked to provide your name and e-mail address and may receive an e-mail to confirm your registration and subsequent e-mail communications to provide updates and reminders and, in some instances, confirmation of your attendance.
- Your use of social media networks and social media account names may be made known to us when you opt to "share" Project Lists via social media sites such as Facebook and Twitter (the information shared is subject to the privacy settings of your social media account);
- Certain features of the Online Services may attempt to determine your geographical location through your IP address; these include:
- the Schluter site selection feature which attempts to redirect end users who may not reside in the United States to the website of the appropriate Schluter affiliate or subsidiary;
- the dealer locator feature which identifies authorized Schluter dealers that are located near you (such feature may also be used when you decide to share your list with local dealers);
- the quote request feature which allows you to request a quote from a Schluter dealer and which identifies nearby Schluter dealers; and
- the event locator and the workshop locator features which identify Schluter related events and workshops that are taking place near you.
- We monitor access to certain Website resources and features by end users and other browsing patterns and history. Any such data will be anonymized and aggregated and will not be associated with you specifically.
- In some instances, we may ask you to provide us with your feedback in terms of your user experience on the Website, with respect to any dealings with any of our dealers or with respect to any of your purchases through the Website. If you choose to provide us with such feedback, you agree that we may use it internally to assess any changes or improvements to the Website, our products, our services (or those of our dealers), our operations, our pricing, our marketing materials and practices as well as our other business practices. If you provide us with contact information, we may contact you to obtain clarifications or obtain your further input.
- The Online Services provides you with various opportunities to "like" us or our products, to "share" information about our products, or to tweet about us or our products. Doing so will reveal information about your social media account and your preferences, subject to the privacy settings of the applicable social media platform.
- Through the use of computer "cookies" we collect data such as your IP address, commercial browser type and version number, domain name, and specific webpages on the Website which you have accessed.
When you send e-mail or other communications to Schluter, we will use your contact information and whatever other information is provided in your communication for the purposes of our review, processing, redirection, escalation, and response to your comments or inquiries. These can include e-mails sent by you via the "Contact Us" feature to make inquiries or report abuse on the website; e-mails sent to personal recipients and authorized Schluter dealers to share Project Lists; or sharing of Project Lists through social media platforms such as Twitter and Facebook.
Clickstream Data & Links
"Clickstream Data" refers to information generated by the activity of users on the Internet based upon the websites and/or webpages they visit, links they click (on a website or in a hyperlink embedded in an e-mail or other electronic document) or features and services they use on a website.
Schluter may also provide on the Website or in e-mails or other electronic documents links to web pages on the Website or on third party websites, and may track the path of these links as followed by the end user.
Schluter uses this information to improve the Website, e-newsletters, services and products it offers and to measure the overall effectiveness of our communications with customers and end users.
When you visit the Website, your web browser will send data about your computer's IP address, type of browser or version, and statistics regarding the time spent on the Website (and/or on particular webpages or sections of the Website) and actions performed on the Website ("Log Data ").
Log Data may also be anonymized and aggregated to compile statistical information which may be used for operational, marketing or other commercial purposes.
3. Sharing of information
Schluter may share information with its affiliates and subsidiaries based in the United States, Germany, Italy, France, Spain, Turkey and the United Kingdom. Schluter will not share information with any other third party except in the following instances:
- with trusted third party service providers that Schluter has retained that access information in order to perform services for Schluter. These may include companies that host, operate, and/or maintain the Online Services; companies that process payments made in conjunction with any purchase of products made through the Online Services; companies supporting fulfillment of product purchases; companies that provide customer service; companies that conduct; customer satisfaction surveys; and companies that support other operational, marketing, financial, or technical matters;
- with business partners that may deliver marketing communications, promotional materials, or advertisements that may be of interest to you;
- with other third parties to whom such disclosure has been authorized through your consent;
- where disclosure is required by or reasonably necessary to comply with law;
- where disclosure is permitted pursuant to applicable laws;
- in conjunction with any outsourcing of Schluter's operations or business processes (or the repatriation of the foregoing);
- in conjunction with any sale of Schluter and/or any of its affiliates, or any of its businesses or parts of its businesses; or
- in conjunction with any litigation procedures.
In all such circumstances, Schluter will ensure that safeguards are in place in regards to such third parties: (i) to restrict use and further disclosure of personal information by such third parties to what is reasonably required to give effect to the purposes outlined above; and (ii) to prevent unauthorized access to as well as unauthorized alteration, disclosure and/or disclosure of personal information.
We may use third-party network advertisers to serve advertisements on the on the Online Services or other online platforms. Network advertisers are third parties that display advertisements based on your use of the Online Services and other online platforms. Third-party ad serving enables us to target advertisements to you for products or services that might interest you. When you use the Online Services, network advertisers may place and access cookies or other technologies on your device or use web beacons to allow them to collect or receive information about your online activities over time and across different online services and to show you advertisements or content you might be interested in. Please visit http://www.networkadvertising.org in order to learn more about the information collection practices and "opt-out" procedures of third-party network advertisers we may use.
4. Where do we keep information?
Your information is kept at facilities and on servers owned and operated by third party service providers retained by Schluter that are located in the United States. Moreover, information associated with any online transaction made through the Online Services is stored in our enterprise resource planning system which is hosted in facilities and on servers located in Germany. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries. By accessing and/or using the Online Services, you consent to such transfer to, and processing in, the United States, Germany, and these other countries.
Cookies and other tracking technologies can serve to recall information previously provided by a web user. A "cookie" is a small text file that may be used, for example, to collect a user's information about website activity. Cookies may contain identifiers that are transferred to your computer's hard drive through your web browser to enable our system to recognize your browser. Employing cookies enables the web server for the Online Services to recognize that you have returned to a specific page. This allows Schluter to track the frequency of your visits and to design and configure the Online Services to make it the most optimal experience for you as a user.
Most browsers are automatically set up to accept cookies. If you wish, you can reconfigure your browser's preferences to refuse all cookies or to indicate when a cookie is being sent. However, if you refuse a cookie, you may not be able to use some of the features available on the Online Services or may need to re-enter previously entered information or selected Website preferences.
6. Do not track signals
7. How do we protect your information?
We have administrative, technical, and physical safeguards designed to protect your information. While reasonable safeguards and security measures are in place to prevent against unauthorized use, access, or disclosure of your information, Schluter cannot guarantee that such safeguards are impenetrable from breaches. You assume the risk of unauthorized use, access, or disclosure of your information that may occur as a result of transmission over networks outside the control of Schluter or access of encrypted information by unauthorized persons.
If you are a registered user, your user information and transaction history may be retrieved through access to your account. The risk associated with the foregoing can be mitigated by using strong a password and changing it frequently. You should take all reasonable steps to secure your account password from unauthorized disclosure and/or use.
8. Phishing and impersonation
"Phishing" refers to attempts made to acquire sensitive information and defraud online account holders. Schluter's policy is to never request any personal information, including credit card information, passwords, usernames, or other login or financial information through unscheduled telephone calls or e-mails. If you have any doubt as to the legitimacy of any such solicitation, you should take reasonable steps to authenticate the solicitation by calling our customer service number, which is posted on the Website. When authenticating a solicitation, please be mindful not to use any hyperlink or telephone number provided in the originating e-mail, as these may also not be authentic.
9. Social media sharing
10. Links to third-party websites
The Website may also contain third party hyperlinks. You acknowledge and agree that we are not responsible for the collection and use of your information by such third parties that are not under our control. We encourage you to review the privacy policies of each website you visit.
11. Retention of information
Information may be retained beyond the realization of the purpose for which it was originally collected (including, without limitation, completion of any transaction or termination of any account on the Online Services): (i) in regards to transactions effected through the Online Services where such retention is necessary, useful or relevant for internal administrative, accounting, technical and operational purposes (including, warranty management, claim management and actual and prospective litigation); (ii) where the information is relevant to litigation or potential litigation; (iii) where such retention is required to comply with applicable laws and regulations; and/or (iv) where such retention is reasonable and otherwise permitted by applicable laws.
12. Account changes and removal
You may correct and update personal information on file with your user account at any time by logging in and making changes under the "Profile" section. Please note that previous information on file will continue to be archived by Schluter.
Deletion of your user account will not automatically result in the destruction of all of your information. We may continue to retain such information to fulfill any outstanding orders, or for archival, security, and/or litigation purposes, or where required by applicable law.
13. Further information
Schluter Systems L.P.
Attn: Legal Department
194 Pleasant Ridge Road
Plattsburgh, NY 12901