Effective Date: December 2, 2015.
1. Why is personal information collected?
The following is a summary of the reasons why personal information is collected in regard to your access of the Website and use of the Online Services:
- personal information is required to make use of certain features of the Website.
- personal information is required to help us improve the Website by better understanding how the Website is being accessed and used by you and other end users
- personal information is required 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
- personal information is required to communicate with you in terms of inquiries that you may make or to send you promotional offers and materials with respect to the Website, our products and/or those of our parent and affiliates.
We may combine or aggregate any of the personal information we collect through access to the Website and/or use of the Online Services, offline, or elsewhere for any of these purposes, including delivering targeted advertisements that are based on your previous online activity on the Website.
2. What personal information is collected and for what purpose is it being collected?
Use of the Website
The following personal information may be collected in terms of your access and use of the Website or certain sections or features of the Website:
- 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 regard 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 personal 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 and 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 personal information in a Project Description or a Project List and later decide to publish such Project Description or Project List, such personal 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;
- Certain features of this Website 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 Canada to the website of the appropriate Schluter affiliate or subsidiary; and
- 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 Website 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.
- 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 personal information
Schluter may share your personal information with its parent, based in the United States, and its affiliates and subsidiaries based in the United States, Germany, Italy, France, Spain, Turkey and the United Kingdom. Schluter will not share your personal information with any other third party except in the following instances:
- with trusted third party service providers that Schluter has retained that require access to your personal information in order to perform the services for Schluter. These may include services in terms of the hosting, operation, and/or maintenance of the Website (including any service or feature of the Website), processing of any payment made in conjunction with any purchase of products made through the Website, any fulfillment of any purchase of products made through the Website, customer service, the undertaking of customer satisfaction surveys or with respect to other operational, marketing, financial, or technical matters;
- to 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 law;
- where disclosure is permitted pursuant to applicable privacy 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, its parent 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 regard 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.
4. Where is your personal information kept?
Your personal information is kept at secure facilities and on secure servers owned and operated by third party service providers retained by Schluter that are located in the United States. Moreover, personal information associated with any online transaction made through the Website is stored in our enterprise resource planning system which is hosted in secure facilities and on secure servers located in Germany. In addition, we may transfer your personal information outside the United States to our affiliates, business partners, and service providers located in other countries. By accessing the Website 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 personal 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 are identifiers that are transferred to your computer's hard drive through our web browser to enable our system to recognize your browser. Cookies can only be read by the website that has set up the cookie. Employing cookies enables the web server for the Website 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 Website 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 Website or may need to re-enter previously entered information or selected Website preferences.
6. Do not track signals
7. How do we protect your personal information?
We have administrative, technical, and physical safeguards designed to protect your personal information. While reasonable safeguards and security measures are in place to prevent against unauthorized use, access, or disclosure of your personal information, Schluter cannot guarantee that such safeguards are impenetrable from breaches. You assume the risk of unauthorized use, access, or disclosure of your personal 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 (which includes personal information) 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 will 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
By choosing to share Project Descriptions and Project Lists via social media platforms (including Facebook and Twitter), information from your social media account may be collected. Your social media account information will not be shared with third parties, and Schluter will not tag, post, advertise, or otherwise share any information through your social media account.
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 personal 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 Personal Information
Personal information may be retained beyond the realization of the main purposes for which it was originally collected (including, without limitation, completion of any transaction or termination of any account on the Website): (i) in regard to transactions effected through the Website 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 personal 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 personal information. We may continue to retain such personal 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 (Canada) Inc.
21100 Ch Ste-Marie
Sainte-Anne-de-Bellevue, Quebec H9X 3Y8