SMART APPLIANCE PRIVACY POLICY

SUB-ZERO GROUP, INC.

Sub-Zero Group, Inc. (“Sub-Zero” or “we”) is committed to protecting the privacy of our customers.  This Smart Appliance Privacy Policy (“SA Privacy Policy”) applies if you use our Smart Appliance Services (the “Services”) and our Sub-Zero Group Owners App (the “App”) to utilize the interactive functions of your Sub‑Zero Smart Appliance.  If you are using our website or you are not using a Smart Appliance, you are governed by the Sub-Zero Privacy Policy located at http://www.subzero-wolf.com/company/general-privacy-policy.

By accepting the terms of this SA Privacy Policy, you are consenting to our collection and use of certain Personal Information and Connected Data.

TYPES OF INFORMATION WE COLLECT

We collect two types of information when you use your Smart Appliance in conjunction with the Services and the App:  PERSONAL INFORMATION AND CONNECTED DATA. 

WHAT IS PERSONAL INFORMATION

Personal Information is information such as your name, address, phone number, email address, product serial numbers and certain demographic information which could be used to identify you (“Personal Information”).

HOW WE USE YOUR PERSONAL INFORMATION

We may use the Personal Information we collect from you, in conjunction with your Smart Appliances, in the following ways:

  • Creation and Support for Your Customer Accounts.  To create, manage and assist you with your accounts and use of our Services or App.
  • 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 Smart Appliance; for warranty registration; and to ensure you are completely satisfied with our products and services.
  • Communications.  To communicate with you about the features of your Smart Appliance and your App account; to advise you of changes to this SA Privacy Policy; in response to your requests; and to provide e‑newsletters and other electronic correspondence from time to time, notifying you of new products and promotions, with the option to unsubscribe if you no longer wish to receive such e‑newsletters and other electronic correspondence.
  • Promotions.  For promotions, sweepstakes and contests.
  • Product Improvement.  To improve our Smart Appliances, the Services and the App.
  • Business and Legal Purposes.  For our internal business purposes, as required by law, in response to a law enforcement request or in response to violations of our Terms of Use and this SA Privacy Policy.

WHAT IS CONNECTED DATA 

Your Smart Appliance is equipped with electronic sensors which permit a two‑way exchange of data between the Smart Appliance and our computer system.  This collection occurs automatically via our computer system, on a continuing basis.  The Connected Data permits you to monitor and direct your Smart Appliance from a remote location, such as turning on your appliance or changing the temperature.  We collect and store the electronic data we receive from your Smart Appliance or from the electronic devices (such as cell phones, computers and tablets) you use to access the Services or the App (“Connected Data”). 

The Connected Data helps us identify and prevent or quickly fix problems with the Smart Appliance.  This also allows us to update security measures for your Smart Appliance.

TYPE OF CONNECTED DATA WE COLLECT

  • Appliance Information.  Serial number, model, parts numbers, MAC address or Wi‑Fi connection of your Smart Appliance; limited information regarding the location of your appliance using your IP address (but not specific geolocation data); information regarding the environmental surroundings of your Smart Appliance (i.e., temperature and humidity); and information about the status and usage of your Smart Appliance; as well as service and diagnostic information for your Smart Appliance, including, but not limited to, temperature settings, power usage, cooking modes (i.e., broil, bake), door open/close information, and refrigerator temperature set point.
  • Device Information.  Information about your operating system, mobile device type and software version.
  • App Information.  Search requests you make using the App; pages viewed using the App; time and duration of visits to the App; and information from your use of the App, such as error or crash reports.
  • Interconnectivity.  Technical information such as functionality, need for maintenance and interactions between the App and the Smart Appliance.

HOW WE USE CONNECTED DATA

We use the Connected Data for the following purposes:

  • Customer Account Support.  To assist you with resetting passwords and other needs for you to utilize the Services and the App.
  • Customer Care and Support.  To install, service, maintain or assist in the repair of your Smart Appliance; to diagnose problems with the Smart Appliance, the Services or the App; for warranty purposes; to assist in identifying the need for parts and the delivery of those parts; and to improve your customer care experience.
  • Software Updates and Messaging.  To provide software updates, text messages, push notifications, email alerts, including notifications of faults, product alerts, end of cycle signals and other similar product notifications.
  • Product Improvement.  To improve our products and services by using data modeling and analytics to improve the efficiency of our appliances and services, and for research and development to design new products and improve our existing products.
  • For Internal Business Purposes.  We will use Connected Data for internal business purposes, such as for market research, data analysis, statistical purposes, sales and marketing, and engineering.
  • For Compliance with Law.  When we are required by law, or in response to a law enforcement request to disclose Connected Information, or in response to a violation of our Terms of Use or this SA Privacy Policy.

WHEN DO WE SHARE YOUR PERSONAL INFORMATION OR YOUR CONNECTED DATA WITH THIRD PARTIES

We only share your Personal Information or Connected Data with third parties in the following limited ways.  We prohibit third parties from using your Personal Information or Connected Data except as required to perform the requested services or as required by law.

  • Affiliates.  To other Sub‑Zero affiliates and subsidiaries, as well as to our distributors and dealers to provide customer care and services.
  • Service Providers.  To carefully selected companies we hire to assist us with:
  1. Installation, delivery, customer care, warranty services, service calls, maintenance, repair, parts or product recalls.
  2. Responding to your questions or comments on our behalf.
  3. Promotions, sweepstakes or contests.
  4. Collecting, processing, analyzing or storing Personal Information and Connected Data in order to improve our products and services and to help us understand customer needs and uses for our Smart Appliances and the App.
  5. Software development.
  6. Data modeling for marketing analysis.
  7. Professional advisors which assist us with our internal business needs on a need-to-know basis, such as for providing us consulting, financial, legal or regulatory advice.
  • At Your Direction.  When you permit us to share your Personal Information with third parties.  Please note, if you request that we share your Personal Information with another company, the Personal Information becomes subject to the other company’s privacy policies, not this SA Privacy Policy.
  • Compliance with Laws and Protection of Legal Rights.  When we are required by law or in response to a law enforcement request to disclose Personal Information or Connected Data in response to a violation of our Terms of Use or this SA Privacy Policy.
  • Business Transactions.  If we were to enter into a business transaction to sell all or a portion of our business to a third party; assign our rights and obligations regarding any of your Personal Information or the Connected Data at the time of a merger, acquisition or sale of all or substantially all of our assets or stock; or in an insolvency, receivership or bankruptcy proceeding.

COMBINATION OF PERSONAL INFORMATION AND CONNECTED DATA

We will store the Personal Information and the Connected Data we collect in separate databases.  We will only combine Personal Information with Connected Data, as described under the SA Privacy Policy.  We limit the number of employees who are authorized to utilize Personal Information in combination with Connected Data.

Protection of Children’s Personal Information

We do not intend for children under the age of 13 to use the Services and the App, or to collect Personal Information from such children.  If you are under age 13, you should not enter any Personal Information about yourself when using the Services or the App.  If you are a parent or guardian who has discovered that your child under the age of 13 has submitted Personal Information without your permission or consent, please contact us at CustomerService@subzero.com, and be sure to include in your message the same information, including email address that your child submitted.  We will make reasonable efforts to remove such Personal Information.

Use of Cookies and Other Tracking Technology

We may collect Connected Data with the use of Cookies.  “Cookies” are small text files a website can use to recognize repeat visitors.  We may use Cookies or other technologies (whether currently available or developed in the future) to customize your experience and otherwise improve and enhance the Services and the App.  You can choose not to accept Cookies by blocking them in your internet or mobile browser or operating system.  To block Cookies, please consult your internet or mobile browser’s help section or operating instructions.  By blocking or erasing Cookies, you may limit or restrict your ability to use certain features and functions of the Services or the App.

We may also use other technologies for the purpose of tracking and researching Connected Data, including web beacons, web logs, pixel tags, passive capture technologies or other technologies.  We will not use geolocation without prior approval from you.

How We Respond to Do Not Track Signals

While Sub‑Zero takes reasonable steps to protect the privacy of the users of its App and Services, we cannot promise or guarantee that our App will address every browser setting or honor every personal browser preference.  We do not react to “Do Not Track” or “DNT” browser signals or similar mechanisms which permit you to exercise choice about the collection of Personal Information and Connected Data over time and across third-party websites or online services at this time.  We do not permit other parties to conduct online tracking on our website.

Security

We maintain administrative, technical and physical safeguards designed to protect against unauthorized access, use, change or destruction of your Personal Information and the Connected Data.  Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure.  While we strive to protect your Personal Information and the Connected Data, we cannot guarantee the security of the Personal Information you transmit to us or the Connected Data transmitted from using the Services, the App or the Smart Appliance.

Security Guidance

We recommend that you take the following steps to protect your Personal Information when you use the Services or the App:

  • Secure Your Home Wi-Fi Network.  Choose a unique SSID/Network Name for your home Wi-Fi network, change the default password to your own unique password, and use a strong method of encryption, such as WPA2.  Please reference your network equipment documentation or contact your internet service provider for instructions and guidance specific to your equipment and services.
  • Password.  Choose a strong password for any account associated with the Services or the App and change the password on a regular basis.
  • Security.  Secure your electronic devices, such as smart phones and tablets.  Use a screen lock password on your device, keep your device updated, and if your device is lost or stolen, please contact your device’s service provider.  If you have an App installed on your lost or stolen electronic device, please contact us at 1-800-222-7820 to let us know and we can suspend access to the Service.

California Privacy Rights

Under California Civil Code Section 1798.83, California residents have the right to obtain:

  • a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes; and
  • a description of the categories of Personal Information disclosed.

To obtain such information, please email your request to CustomerService@subzero.com.

Links to Other Websites

We are not responsible for any content offered on any third-party websites or applications.  Links to third-party websites or applications are provided for your convenience only.  This SA Privacy Policy will not apply to any Personal Information that you provide to, or that is collected by, any third-party website operator or third-party product/service 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 SA Privacy Policy.

Social Media Sites

The Services and the App may include social media features such as Facebook or Twitter.  These social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button, regardless of whether you click on the button.  Your use of these features is governed by the company’s privacy policy providing the social media feature, not by this SA Privacy Policy.  You should review your privacy settings on social media sites that you use.

UPDATES

We may, from time to time, update this SA Privacy Policy.  We will prominently display that we have updated our SA Privacy Policy when you visit our website and when you access the App.  We may provide electronic notice of an update to your registered electronic device or email address.

Your continued use of the Services or the App indicates your acceptance of all updates.

Transfer of Information

We operate globally and may transfer your Personal Information to third parties in locations for the provision of services, as described in this SA Privacy Policy.  If we transfer, store or process your Personal Information, we will take reasonable steps to safeguard the privacy of your Personal Information. 

QUESTIONS

If you have questions regarding this SA Privacy Policy or the way we use your Personal Information or the Connected Data, please contact Customer Care at 1-800-222-7820.

Last Updated:  July 11, 2017