Privacy Notice

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1. INTRODUCTION

1.1 This Privacy Notice (“Notice”) describes the information that Hot Water Plumbing, LLC collects, uses, shares and stores about you, including personal data, and provides guidance and information regarding our processing of personal data. For purposes of this Notice, Data Protection Legislation generally defines “personal data” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

1.2 We are committed to protecting and respecting your privacy. This Notice sets out the legal bases we rely on when processing any personal data, we collect from you that you provide to us, either directly or through our trusted partners, or that we obtain from others. Please read this Notice carefully to understand how we process personal data about you.

1.3 In this Notice, references to “you” means the person about whom we collect, use and process personal data.

1.4 We will use personal data about you only for the purposes and in the manner set forth below, which describes the steps we take to ensure that our processing of personal data complies with U.S. laws and regulations, including the California Privacy Rights Act (“CPRA”), Canadian Privacy laws and regulations, as well as with European Union Law, including Regulation (EU) 2016/679, known as the General Data Protection Regulation GDPR, any subsequent amendments or successor laws thereto, and if applicable any local national laws implementing the GDPR (collectively referred to as “Data Protection Legislation”).

1.5 We seek to maintain the privacy, accuracy, and confidentiality of data (including personal data about you) that we collect and use.

2. WHEN DOES THIS PRIVACY NOTICE APPLY

2.1 This Notice applies to personal data that we collect, use, disclose and otherwise process about you in connection with your relationship with us. This includes personal data we collect about you, or you provide to us, through our websites, mobile applications, or call centers; through product registrations; and through any other online or offline methods through which we communicate with you, as well as when we obtain personal data about you from a third party. It does not apply to Hot Water Plumbing, LLC employees or to those applying for jobs with Hot Water Plumbing, LLC. While this Notice is inter alia designed to comply with privacy requirements across the United States, it is not meant to imply that all state privacy laws necessarily apply or apply across all categories of personal data.

3. PROCESSING OF YOUR PERSONAL DATA

3.1 The personal data we collect about you helps us provide the best possible support for your products, optimize your use of our websites and mobile applications, and show advertisements to you based on your interests. In addition, we are required to process certain personal data for legal, regulatory, tax and auditing purposes. The personal data we collect, the basis for our processing, and the purposes of our processing, are detailed below. Sometimes, these activities are carried out by third parties (see “Sharing of Personal Data” section below).

3.2 You are not required to provide all the personal data described below to us; however, if you choose not to do so, we may not be able to offer you certain services and related features. 

Additional Information for California Residents

The personal information that we collect from you may include information within the below categories of data. These categories also represent the categories of personal data that we have collected over the past 12 months. Note that the “category of data” column listed below refers to the category of personal data as defined under the California Privacy Rights Act (“CPRA”). Inclusion of a category in the list below indicates only that we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category.

We only process sensitive personal information for those purposes necessary to provide this service.

3.3 Where does Hot Water Plumbing, LLC obtain personal data about me?

Information you provided to Rheem:

We obtain personal data about you directly from you providing to Rheem, or via contractors and plumbers who assist you, when you register a product, when you extend a warranty, and when you submit information to us via our websites or mobile applications. We may also collect personal data during the performance of your contract with us or if you contact us via phone, email or direct messaging services provided by third-party social media platforms.

Information we collect automatically:

As discussed above, when you navigate through and interact with our websites or mobile applications or through email, we may use automatic data collection technologies to collect information about you. This includes browser cookies, Flash cookies, web beacons, device identifiers, server logs, and other technologies.

Some content or applications, including advertisements on our websites, are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our websites, but only with your consent. Third parties that collect such information may associate it with your personal data were permitted by law, or they may collect information, including personal data, about your online activities over time and across different websites and other online services. They or Rheem may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not track information about an individual consumer’s online activities over time and across third-party websites or online services (i.e. cross-contextual behavioral advertising) except with your specific, opt-in consent. Accordingly, we do not monitor or take any action with respect to Do Not Track signals (including the Global Privacy Control signal). 

Information we obtain about you from third parties:

We may receive personal data about you from contractors or plumbers who may assist you in registering your products and purchasing extended warranties.

We also send out mailings via the post office from public records.

4. SHARING OF PERSONAL DATA

4.1 We do not sell personal data for any commercial or marketing purposes, have not sold personal data in the preceding 12 months and will not sell personal data. We also do not share personal data for cross-context behavioral advertising.

4.2 The following are limited circumstances where we may share your personal data with third parties:

4.2.1 External vendors, service providers, and technicians who help with our data processing and storage.

4.2.2 In connection with a merger or sale of the company and/or parts of its assets, your personal data may be transferred as part of the merger or sale.

4.2.3 Contractors or plumbers who may assist you in registering your products or purchasing extended warranties or performing diagnostics or service.

4.2.4 Third parties who you have requested information from us for purposes of financing or rebate information.

4.2.5 Affiliates, subsidiaries, divisions, and service providers who provide services to us or on our behalf.

4.2.6 Third parties who assist us in providing our products and services and to help us understand your use of our products.

4.2.7 External professional advisors.

4.2.8 Select third party vendors, business partners, conference sponsors/exhibitors and other companies so that they can send promotional materials about products and services (including special offers or promotions);

4.2.9 For any other purpose disclosed by us when you provide the information; and

4.2.10 With your consent.

We endeavor to require all service providers that we share personal data about you to provide assurances regarding the confidentiality and security of that information, including to only use such information for the purpose for which it was provided and in accordance with this Notice.

Sharing of personal data excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

4.3 We may also disclose your personal data:

4.3.1   To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

4.3.2   To enforce or apply our terms of use and other agreements (including warranties) and for billing and collection purposes.

4.3.3   If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Rheem, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4.3.4   To others, where it is permitted by law.

5. INTERNATIONAL DATA TRANSFERS

5.1 From time to time your personal data may be transferred, stored and processed in foreign countries, including the United States, with different privacy laws that may or may not be as comprehensive as the Data Protection Legislation in your home country or may not be subject to an adequacy decision (as applicable) by the European Commission or the United Kingdom. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the that country may be able to obtain access to your personal data through the laws of the foreign country. For transfers of personal data to foreign countries, we take additional steps in line with all applicable laws, including European and Canadian Data Protection Legislation. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights. Whenever we engage a service provider in a foreign country, we require that its privacy and security standards adhere to this policy and applicable Data Protection Legislation.

6. HOW IS MY PERSONAL DATA SECURED

6.1 We operate and use reasonable administrative, technical and physical security measures to protect your personal data.

6.2 We have taken security measures to protect personal data about you from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data about you. Access is granted on a need-to-know basis to those employees and other people whose roles require them to process personal data about you.

7. RETENTION OF PERSONAL DATA

7.1 We will keep personal data about you for as long as it is necessary to fulfill the purposes for which we process it as described above in Section 3, or if we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data. This may mean that we will retain some information about you for longer than we retain other information. The criteria we use to determine data retention periods for personal data includes the following:

7.1.1 Retention of user account details; we will retain it for a reasonable period after the relationship between us has ceased.

7.1.2 Retention in case of queries; we will retain it for a reasonable period after the relationship between us has ceased.

7.1.3 Retention in case of claims; we will retain it for the period in which it may be enforced; and

7.1.4 Retention in accordance with legal and regulatory requirements; we will consider whether we need to retain any additional period because of a legal or regulatory requirement.

7.2 Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose, including sharing it with utility companies, without further notice to you or your consent.

7.3 If you would like further information about our data retention practices, please contact us.

8. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS AND OTHER US STATE RESIDENTS

8.1 Depending on your residency, you may be entitled to the following rights under the California Consumer Privacy Rights Act (“CCPA”) or other US state privacy law, subject to certain conditions and limitations. We may choose to provide these rights, even if we are not required to do so.

8.1.1 RIGHT TO KNOW
You may request to receive, in a portable and, to the extent technically feasible, readily usable format:

(1) The categories of personal information
(2) The categories of sources from which the personal information is collected
(3) The business or commercial purpose for collecting or selling personal information
(4) The categories of third parties with whom we share the personal information
(5) The specific pieces of personal information we have collected about you (although note that we cannot provide you with sensitive personal information)

8.1.2 RIGHT TO DELETE

You may request that we delete any personal information about you which we have collected. If it is necessary for us to maintain the personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal data when you request us to do so, we will inform you and tell you why we are not deleting it.

8.1.3 RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL DATA

As stated above, we do not sell personal information or share it for cross context behavioral advertising.

8.1.4 RIGHT TO LIMIT THE USE OR DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

As stated above, we only process sensitive personal information for necessary purposes.

8.1.5 NO DISCRIMINATION

You will not be discriminated against because you exercised any of these rights.

8.2 HOW TO SUBMIT A REQUEST

To exercise certain rights, you must submit a verifiable request to us directly at office@hwppro.com and providing the requested information.
 

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity, and value of the personal data that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. We may also require you to provide a written declaration that you are who you say you are.
 

You may designate an authorized agent to make a request to know or delete on your behalf by submitting a signed declaration of representation.
 

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
 

We will notify you if we are unable to honor your request. Based on your residency, you may have the right to appeal our decision with regard to your request by contacting us directly at office@hwppro.com .

8.3 HOW WE COLLECT, USE AND SHARE PERSONAL DATA OF CONSUMERS

8.3.1 Categories of Personal Data and Business Purposes for Collection

The categories of personal data we have collected from Consumers in the past twelve (12) months and the business purpose(s) for collecting the information are listed above in Section 3.2.

8.3.2 The Sources of Collection

The sources from which we might collect personal data about you are listed above in Section 3.3.

8.3.3 Who We May Share Your Personal Data

The categories of third parties we may share your personal data with are listed above in Section 4.2

8.4 PERSONAL DATA OF MINORS

Rheem does not intentionally collect or process personal data about minors under the age of 16.

9. SHINE THE LIGHT LAW

Annually California residents may be able to request and obtain information that Rheem shared with other businesses for their own direct marketing use within the prior calendar year (as defined by “California’s Shine the Light Law”). If applicable, the information would include a list of categories of Personal Data that was shared with the names and addresses of all third parties that Rheem shared this information in the immediately preceding calendar year. To obtain this information under the Shine the Light Law, please send an email to office@hwppro.com with “California Shine the Light Privacy Request” in the subject line.

CONTACT FOR MORE INFORMATION

If you have any questions or concerns about Hot Water Plumbing, LLC. Privacy Notice and practices, please contact our Chief Privacy Officer at Hot Water Plumbing, LLC., Attn: Chief Privacy Officer, 7280 NW 87th Terrace, Suite C-210, Kansas City, MO 64153-3720.

10. ADDITIONAL RIGHTS FOR NON-U.S. RESIDENTS

You may have various rights under data protection legislation in your state or country (where applicable).

To the extent permitted by applicable law and subject to certain conditions, you may (1) seek confirmation regarding whether Rheem is processing personal data about you; (2) request access to the personal data that we maintain about you; (3) request that we update, correct, amend or erase or restrict information about you; or (4) exercise your right to data portability, by contacting us directly at office@hwppro.com. In addition, you may object to Hot Water Plumbing, LLC.’s processing of your personal data at any time; however, doing so may impact your use of the services that we provide. To protect your privacy, Rheem will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal data. We may ask that you provide us with your name, postal address, email address, telephone number, and/or equipment serial number.

11. IDENTITY OF THE CONTROLLER OF PERSONAL DATA

For the purposes of Data Protection Legislation, the Data Controller is Hot Water Plumbing, LLC., a U.S. organization with its principal place of business at 7280 NW 87th Terrace, Kansas City, MO 64153

12. YOUR RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY

Without prejudice to any other administrative or judicial remedy you might have, you may have the right under data protection legislation in your country (where applicable) to lodge a complaint with the relevant data protection supervisory authority in your country if you consider that we have infringed applicable data protection legislation when processing personal data about you. This means the country where you are habitually resident, where you work or where the alleged infringement took place.

13. CHILDREN’S PERSONAL DATA

The products and services that we offer are designed for a general audience and are not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. If we learn we have collected or received personal data form a child under the age of 16, we will promptly delete the information.

14. UPDATES TO PRIVACY NOTICE

We reserve the right to change this Notice at any time in our sole discretion without prior notice to you to reflect changes. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Notice to check for any changes. We will indicate at the top of the Notice when it was most recently updated. Accordingly, please refer back to this Privacy Notice frequently as it may change.

15. CONTACT US

For further information or if you have any questions or queries about this Privacy Notice, please contact the Chief Privacy Officer, Hot Water Plumbing, LLC. 7280 NW 87th Terrace, Kansas City, MO 64153, or call (816) 890-9696. Alternatively, in writing to office@hwppro.com . We have procedures in place to receive and respond to complaints or inquiries about our handling of personal data, our compliance with this Notice and with applicable privacy laws.