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 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.
- Promotions. For promotions, sweepstakes and contests.
- Product Improvement. To improve our Smart Appliances, the Services and the App.
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 App and the Services permit 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.
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:
- Installation, delivery, customer care, warranty services, service calls, maintenance, repair, parts or product recalls.
- Responding to your questions or comments on our behalf.
- Promotions, sweepstakes or contests.
- 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.
- Software development.
- Data modeling for marketing analysis.
- 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.
- 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
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 email@example.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.
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.
We maintain appropriate administrative, technical and physical safeguards and current security standards designed to protect against unauthorized access, use, loss, theft, disclosure, misuse change or destruction of your Personal Information and the Connected Data whether recorded on paper or captured electronically. 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.
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
Social Media Sites
FOR CANADIAN RESIDENTS:
CHIEF PRIVACY OFFICER
Email us at: firstname.lastname@example.org
Call us at: 1-800-222-7820
Our privacy officer is a person within Sub-Zero who, in accordance with Article 30 of the Federal Law on Protection of Personal Data in the Possession of Private Parties, has been formally designated to:
- Oversee the protection of both Personal Information and Connected Data
- Respond to requests related to our use of your Personal Information and Connected Data
For everything related to the processing and protection of personal data, you can contact our privacy officer by sending an email to CustomerService@subzero.com.
How To Access, Rectify, Cancel, And Object To The Use Of Your Personal Information
You have a right to know which of your personal data we hold, the purposes for its use, and the conditions of use (Access). Moreover, you have the right to request any correction or clarification of your Personal Information, should this information be outdated, incomplete, or somehow incorrect (Rectification); you also have the right to eliminate your Personal Information when you consider that this information is not being used according to guidelines, duties and obligations, as stated in the law (Cancellation); as well as oppose the use of your Personal Information for specific purposes (Objection). Collectively, these rights are known as Access, Rectification, Cancellation, and Objection rights (ARCO Rights).
To exercise any of the ARCO Rights, you will have to submit the respective request through an email addressed to our Privacy Officer. In accordance with Article 29 in Mexico's Federal Law on the Protection of Personal Information held by Private Parties, the request must contain information requested on all required fields and marked as mandatory, including: complete name (including last name(s)), email address or postal address for notifications, a contact telephone number, and a clear and exact description of the personal data for which ARCO Rights are being exercised. The form should be accompanied by a copy of an official form of ID, or be included in a legible electronic file (scanned). The term to reply to your notice will be no more than twenty (20) working days, as of the date the request is received, and will be responded to directly by email to the address the request came from.
You can revoke your consent, which you may have granted us, for the management of your Personal Information. However, it is important that you are aware that we cannot comply with such request in all cases, or stop using the information immediately, and that due to a legal obligation, we must continue managing your Personal Information. Likewise, we ask that you please consider that for certain purposes, revocation of consent would mean we are not able to continue providing you with requested services, or it might also imply an end to your relationship with us.
Improper Use of your Personal Information or Connected Data
If you think that your right to protection or your Personal Information is somehow being unduly used, due to the behavior of an employee, our performance, our responses, or if you consider that any part of the treatment given to your Personal Information is in violation of what is set forth in the Federal Law on the Protection of Personal Data held by Private Parties, you may reach out to Mexico's IFAI with an official complaint. For more information, please visit their website at ifai.org.mx.
Your continued use of the Services or the App indicates your acceptance of all updates.
Transfer of Information
Last Updated: 2/15/2018