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Privacy Policy

Last Updated / Effective Date January 1. 2020


Sub Zero Group, Inc. (collectively, "Company," "our", "we," or "us") is committed to protecting the privacy of our customers when we interact with you offline and online at subzero-wolf.com (our "Site"). This privacy policy ("Privacy Policy") provides information about how we collect, use, share and safeguard the Personal Information we gather from you.  Certain capitalized terms not defined in this Privacy Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).

If you use this Site, you must comply with our Term of Use (“Terms”) found here.


WHAT IS PERSONAL INFORMATION?

Personal Information is any 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.  Please see the chart below for more details about the categories of Personal Information we collect.  This Policy does not apply to any information that is publicly available.


PERSONAL INFORMATION WE COLLECT.

We collect the following categories of Personal Information.

 

Category of Personal Information

Data Element

Category of Sources From Which Personal Information Was Collected

Purposes for Collecting

Third Party with Whom the Personal Information is Shared

Identifier

IP Address; Unique personal identifier; Email Address; Real Name; Postal Code; Phone Number; Device Name; Mailing Address; Project Type

 

Website cookies; Website Server Logs;

Booking Bug Landing Page; Adobe tracking;

Website Forms

  • Identifying region user is visiting from
  • Categorizing unique visits/network providers
  • Logging visits from unique network provider
  • Responding to requests to schedule showroom appointments
  • Responding to inquiries about our products
  • Advertising new products and promotions

Independent Distributor partners

Internet Activity

Browsing history; Performance/telemetry statistics; Errors encountered; Device type; Browser preferences and version; Showroom location preference; Visited URL;

Website cookies; Booking Bug Landing Page; Website Forms

 

  • Ensuring performance and availability of the website
  • Monitoring/troubleshooting site issues
  • Alerting to issues/problems
  • Responding to inquiries about our products

 

 

Independent Distributor partners

Geolocation Data

City, State, Zip, Country (based on IP Address)

 

Adobe tracking

  • Responding to inquiries about our products
  • Advertising new products and promotions

None


CATEGORIES OF SOURCES OF COLLECTION


We generally collect Personal Information in three ways:  (1) you provide Personal Information directly to us, (2) we automatically collect Personal Information from you when you use our Site (e.g. cookies), or (3) we receive Personal Information about you from third-party sources (e.g. from public sources).


We Collect Personal Information You Provide.

Accounts.  We collect a subset of the data contained in the table above when you create an account with Sub-Zero through our Site.

Marketing Communications.  We use this data to send you promotional and other electronic and hardcopy communications. We may use third-party providers to deliver communications to you. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at CustomerService@subzero.com 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 all other communications from us.

Feedback.  When you provide comments or feedback about our Site, the content on the Site, or our products or services ("Feedback"), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you.  Feedback will be used without attribution or compensation to you.

Applying to Work with Company.  To submit job application materials online to work with Company, you will be redirected from our Site to a website operated by a third party. You may be required to create an account with that third-party host. We encourage you to review the terms and privacy policy posted on that third-party’s website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with Company and its affiliates.

Sweepstakes & Contests.  We may offer sweepstakes or contests. To participate you must submit certain data, which may include your name, email, organization name and type, phone number, physical address, and other Personal Information. Data collected via sweepstakes and contests will be (i) used to contact you with promotional and related communications, (ii) shared with third-party vendors, and (iii) subject to additional terms provided to you at such time.


We Collect Personal Information Automatically

More about targeted advertising

We may allow our third-party service providers to collect information about your online activities so that these entities can provide services to us.  We have described those activities in further detail in the chart above.  These and other third parties may collect or receive information about your use of our Site and our products, including through the use of cookies, web beacons, and other tracking technologies. This information may be collected over time and combined with information collected from other sites and online services. These third parties may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits over time and across different websites, including our Site. These third parties may participate in the Network Advertising Initiative and/or the Self-Regulatory Program for Online Behavioral Advertising. These programs allow users to opt out of targeted advertisements offered by participating companies. You can learn more about these programs at http://www.networkadvertising.org/ or http://www.aboutads.info/. To limit or opt out of targeted advertisements by participating companies, please visit http://www.networkadvertising.org/managing/opt_out.asp or http://www.aboutads.info/choices/. Note that we do not have control over these targeted advertisement programs or the companies that participate in them.

More about cookies and other trackers

Automated Data.  We automatically collect certain information from you when you access our Site. For example, we may collect information such as the websites you visit before or after you visit the Site, pages you click-on on the Site, IP address, location information, search requests, browser type, operating system, data and time you visit the Site, the amount of time spent on the Site, and the device you use to access the Site.

What types of online tracking mechanisms do we use?  We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site.

What are cookies and web beacons / pixel tags?  A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

How long do Cookies last?  A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

We are not responsible for third-party Cookies.  Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over third-party Cookies. Third-party Cookies are not governed by this Policy.

How do you manage Cookies or opt-out?  Most browsers automatically accept cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.


We Collect Personal Information From Third-Party Sources.

We obtain data about individuals from various third-party companies and public sources and we may combine that data with Personal Information or other data we collect. This enhances our existing data about our users (e.g., adding address data), improves our ability to contact you, and enhances our marketing capabilities.


PURPOSES FOR COLLECTING PERSONAL INFORMATION.

As further detailed in the table above, we use Personal Information listed above for the following purposes:

As Stated or Agreed to at the Point of Collection.  We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

Administration.  We use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, to understand the Site’s demographics and user preferences, for evaluating applications, and managing profiles.

Site Management.  We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

Advertising and Notice.  We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Site, to notify you of changes to our Terms or this Policy, and for other similar communications.

To Protect Our Rights.  We may use Personal Information to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site.


DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

As further detailed in the chart above, we will only share your Personal Information with the following categories of third parties:

Employees, Affiliates, Dealers and Distributors.  We may share your Personal Information with our employees, affiliates, subsidiaries, dealers and distributors who have a need to know the information for our business purposes.

Service Providers and Third Parties.  We may share your Personal Information with our Service Providers that provide service to us and only in accordance with contractual provisions which require those Service Providers to protect your Personal Information.  For example, when required to complete a purchase or to provide installation, maintenance or services for your appliances; when required to help us collect and analyze Personal Information; when required to share your IP address in cooperation with internet service providers to identify users; with Service Providers to help us host and manage the Site; to provide targeted advertising and other marketing; to improve the content and functionality of the Site; to perform data analysis and statistical analysis; to troubleshoot problems with the Site; to provide payment processing services; to provide public relations; to provide email services; to provide data processing; and to support or provide the security of the Site.

Government Officials / Law Enforcement.  We may share your Personal Information when we are required by law or court order, or other governmental order or process to disclose such Personal Information, or if we believe in good faith that the law requires it; if we deem it necessary to comply with laws or to enforce compliance with our Terms of Use, or to protect our Site, customers, or others; and when disclosure is necessary to identify, contact, or bring legal action against someone who may cause or be causing harm to, or interference with your appliances, our information technology systems and equipment, your privacy or your property.

Professional Advisors.  We may share Personal Information with certain service providers that are our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Company.

Change in Ownership.  We may share your Personal Information with an actual or prospective subsequent owner of our company, including at the time of a merger, acquisition, due diligence process, or sale of all or substantially all of our assets or stocks to a subsequent owner or operator.

Other.  We may share Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Use and Disclosure of De-Identified or Aggregated Information

Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Company is the sole and exclusive owner of such de-identified and aggregated information, including if Company de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.


HOW WE RESPOND TO DO NOT TRACK SIGNALS (CALIFORNIA)

We do not react to "Do Not Track" or "DNT" browser signals at this time.


SECURITY

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

NO DATA TRANSMISSION OVER THE INTERNET CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE THE SECURITY OF ANY INFORMATION (INCLUDING PERSONAL INFORMATION) YOU TRANSMIT TO US, AND YOU PROVIDE SUCH INFORMATION AT YOUR OWN RISK.


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 transmit 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 us an email at CustomerService@subzero.com and be sure to include in your message the same information, including email address 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.


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 the Company 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 Privacy Policy to receive this information.


CALIFORNIA CCPA RIGHTS

The CCPA provides additional rights to California residents. Subject to exceptions permitted by applicable laws and verification of your identity, if you live in California, you may exercise the following rights with regard to your Personal Information.

Right to Access

You have a right to access any of the following that occurred in the prior 12-month period:

  • The categories of Personal Information we collected from you;
  • The categories of sources from which the Personal Information was collected;
  • The specific pieces of Personal Information that we have collected from you (i.e. "data portability");
  • The categories of third parties with whom we shared your Personal Information;
  • The categories of Personal Information that we Sold or disclosed for a Business Purpose; and
  • The business or commercial purpose for collecting or selling your Personal Information.

Right to Deletion

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

Using an Authorized Agent

You have a right to submit requests to exercise your rights under the CCPA through an authorized agent that you have authorized in writing to act on your behalf. You will still be required to verify your identify as described in this Privacy Policy as well as the identity of 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.

How to Exercise Your Rights of Access and Deletion.

How to Exercise Your Rights.  To exercise your rights described in this Privacy Policy, you may submit your request to us by contacting us at any of the following:


+1-800-222-7820
https://www.subzero-wolf.com/assistance
CustomerService@subzero.com

More on Submitting a Request to Delete.  You may submit your request to delete your Personal Information here: https://www.subzero-wolf.com/assistance

Who May Exercise Your Rights..  You may only make a request to exercise your rights on behalf of yourself. A parent or legal guardian may make a request on behalf of their child. If you are a California resident, only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your Personal Information. See the section titled "Authorized Agents" for more information.

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

When We Will Respond.  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.

Non-Discrimination

You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.


LINKS TO OTHER WEBSITES

We are not responsible for any content offered on any third-party websites. Links to third-party websites are provided for your convenience only. This 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.

We are active on social media, including Facebook, Twitter, and LinkedIn. Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our social media pages any comments or content that you post on our Social Media pages.

Our Site may include social media features such as Facebook or Twitter buttons (such as "Like" or "Tweet"). These websites 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 privacy policy of the company providing the social media feature, not by this Privacy Policy. You should review your privacy settings on social media sites that you use.


CHANGES TO POLICY

WE MAY, AT ANY TIME, REVISE THIS PRIVACY POLICY BY UPDATING THIS POSTING. IF WE MAKE A SIGNIFICANT CHANGE TO THIS PRIVACY POLICY, WE WILL PROMINENTLY POST THE CHANGES ON OUR SITE.  ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING.

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 by the in other jurisdictions.


APPLICABLE LAW

This Privacy Policy is governed by Wisconsin and United States laws, excluding their conflicts of laws principles.


ADDITIONAL WAYS WE WILL COMMUNICATE WITH YOU

We may contact you if we receive a service notification for your registered appliance, or to issue other notices concerning the safety of your appliance.

We may also contact you in response to a communication from you about new products or services, to provide a promotional e-mail, to arrange for and provide service and maintenance services, to send you information about your products such as service and warranty information, and we may contact you about your orders or your accounts.

If you do not wish to receive promotional e-mails from us, you may opt-out by clicking the unregister button at the bottom of that email.


FURTHER QUESTIONS

If you have any questions or comments about our Privacy Policy, please contact us at (800) 222-7820.

 

 

 

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