Last Updated: August 2, 2019
SUMMARY OF KEY PROVISIONS
I. Information we collect including our use of tracking technologies
II. How We Use Information
We use your information to: confirm and fulfill your order, provide customer service - including product maintenance and troubleshooting, and to send you marketing communications.
III. Data Sharing
We may share your Personal Information with our affiliates and service providers, and as required by law, to enforce our rights, or in connection with a business transfer. We will share your Personal Information with third party advertising partners only with your consent.
IV. Interest-Based Advertising
V. Your Rights: Choice & Access
You may ask us not to share your information with third parties for marketing purposes and may opt-out of receiving marketing messages from us by contacting our Privacy Office or by using the unsubscribe link in our emails. You may correct your information or delete your account using the My Account page on the Website.
VI. Data Security
We take reasonable steps to protect your information, but please be aware that no transmission of information over the Internet is 100% secure.
VII. Third Party Services
VIII. Use By Children
Our Websites are not directed to children under the age of 13.
IX. Updates to This Privacy Notice
Please review the “Last Updated” legend at the top of this page to determine when this Policy was last revised.
X. Contact Us
firstname.lastname@example.org or FOTILE America LLC, 6 Campus Dr Suite 210, Parsippany, NJ, 07054, United States
Information we collect including our use of tracking technologies
We collect two types of information: Personal Information and Other Information. “Personal Information” is information that can be used to identify you as an individual. “Other Information” is information that does not reveal an individual’s specific identity or does not directly relate to an identifiable individual, including information that has been de-identified or aggregated.
1. PERSONAL INFORMATION WE COLLECT
Information You Provide to Us. When you sign up for a FOTILE account, contact us, sign up to receive communications from us , submit your product registration, or a contest entry (either online or offline), we may ask you to provide your Personal Information, which may include:
· Your contact information, such as your name, email address, mailing address, and phone number
· Your billing information, such as your credit card number and billing address
· Your FOTILE account information, including your user name, account number, and a password
· Your product and ownership information
· Your preferences, such as product wish lists, order history, and marketing preferences
Information Provided From Third Parties. We may also receive Personal Information about you from third- party sources, including commercially-available sources, social media platforms, and providers of third-party products or services, and combine such Personal Information with other Personal Information that we have collected.
2. Other Information
Usage Information. FOTILE and its business partners and service providers may use a variety of technologies that automatically or passively collect information about how you interact with our Websites ("Usage Information"). Usage Information may include:
· Your IP address, which is an unique set of numbers assigned to your computer by your Internet Service Provider (ISP) (which, depending on your ISP, may be a different number every time you connect to the Internet);
· The type of browser and operating system you use; and
· Other information about your online session, such as the URL you came from to get to our Websites and the date and time you visited our Websites.
In addition to using this information from our log files to better understand how our Websites are used, we may use this information to troubleshoot technical problems, maintain online safety and security, and if necessary, prohibit or restrict access to our online services.
The technologies used to collect Usage Information include but are not limited to:
We use both session ID cookies and persistent cookies:
· A session ID cookie expires when you close your browser. We use session cookies to make it easier for you to navigate our Websites.
· A persistent cookie remains on your hard drive for an extended period of time. We set a persistent cookie to store your account settings so we can identify you the next time you visit or enable some functions on our Websites. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our Websites.
You can delete cookies by following the directions provided in your Internet browser’s “help” file. If you reject cookies, you may still use our Websites, but your ability to use some areas of our Websites may be limited.
B. “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
C. “Local Storage/Local Shared Objects”. We use Local Shared Objects (LSOs) such as HTML5 or Flash on our Websites to store content information and preferences. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your web browsing activity use LSOs such as HTML5 or Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here.
D. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Website. They can be embedded within a web page or included in an e-mail message, and are usually invisible to the human eye. When we use web beacons within our web pages, the web beacons (also known as “clear GIFs” or “tracking pixels”) may tell us such things as: how many people are coming to our Websites, whether they are one-time or repeat visitors, which pages they viewed and for how long, how well certain online advertising campaigns are converting, and other similar Website usage data. When used in our e-mail communications, web beacons can tell us the time an e-mail was opened, if and how many times it was forwarded, and what links users click on from within the e-mail message. Based on this information, we can adjust the content, products, services, and promotions we provide you to better meet your interests, as well as make you aware of FOTILE products, services, and/or special offers in which you may be interested.
E. “De-Identifying or Aggregating Information”. We may de-identify or aggregate Personal Information to create other Information. For example, we may aggregate Personal Information to calculate the percentage of our users who use our Websites within a particular zip code/postal code.
I. HOW DO WE USE YOUR PERSONAL INFORMATION?
Personal Information. We use Personal Information that we collect generally to fulfill any orders placed through the Website (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Personal Information to:
· Communicate with you;
· Screen our orders for potential risk or fraud; and
· When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
Other Information. We may use Other Information for any purpose, unless prohibited by law. Where Other Information is combined with Personal Information, we will treat this combined information as Personal Information as long as it is combined.
II. DATA SHARING
We may share Other Information, such as de-identified or aggregated data and Usage Information, with third parties. We may also share your Personal Information as disclosed at the time you provide your information, and in the following circumstances:
With Our Service Providers. We may share your Personal Information with our third-party service providers to allow them to provide services to us (such as data analysis, surveys, data hosting, information technology, payment processing, customer support, warranty services, email delivery, and auditing).
With Third Party Advertising Partners. With your consent, we may share your Personal Information with other trusted third parties to allow them to send you marketing communications about their own products and services.
Legal Disclosure: We also may use or disclose Personal Information or Other Information as we believe necessary:(1) if we determine a policy violation has occurred, or to enforce our terms of service;(2) if we believe such disclosure is necessary to identify, contact, or bring legal action regarding injury or interference with the rights and property of FOTILE or its affiliates, including, but not limited to, to enforce our right against unauthorized access or attempted unauthorized access to our information technology assets or against other inappropriate use of our Websites, products, or services;
(3) to comply with laws, regulations, court orders and subpoenas or similar requests for information by authorities, or as required by law;
(4) to protect your safety and the safety of others; and
(5) to assist us in fraud prevention or investigation.
Business Transfer. We may disclose Personal Information or Other Information in connection with a reorganization, merger, sale, joint venture, assignment, transfer of other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
III. Interest-Based Advertising
Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Websites do not support Do Not Track requests at this time.
Please note that even if you choose to remove your information (opt-out), you will still see advertisements while you're browsing online. However, the advertisements you see may be less relevant to you and your interests.
IV. Your Rights: Choice & Access
Your Right to Opt-Out. You may, at any time, inform us that you do not want FOTILE to use your Personal Information to provide you with offers or send you newsletters, emails or other marketing communications, by sending your request to us at email@example.com, or by mail to FOTILE America LLC, 6 Campus Dr. Suite 210, Parsippany, NJ, 07054, US
You may also use the above contact information to withdraw your previous consent to share your Personal Information with third parties (other than our service providers).
You may also unsubscribe from receiving promotional communications from our brands by clicking on the unsubscribe link provided in that brand’s promotional email message. However, please note that you cannot opt-out from all communications, as FOTILE and its brands may need to send you information related to our products (e.g., warranties, service reminders), your orders, or your accounts.
To request removal of your Personal Information from our message boards, blogs, or other interactive features on our Websites, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Your Right to Review/Correct. You may review, correct, or update your Personal Information by contacting us as set out above, or if you are a registered user of our Website(s), by accessing the My Account/Owner Center page on the Website. After your account is deleted/terminated, your information may not be deleted in its entirety from our systems or the systems of our supplier platform used to provide our services. We may retain backup copies of your information, including personal information on our servers or database (and/or any authorized third partner servers or databases we use) to assist with any legal obligations, resolve disputes, and enforce our agreements. We will retain your information for as long as necessary to fulfill the purposes of processing described in this Notice.
California Residents: Your California Privacy Rights. If you are a California resident, you may have the right to request and receive certain information about disclosure of your Personal Information to third parties for their direct marketing purposes. Because it is our policy not to share your Personal Information with third parties for third-party direct marketing purposes without your consent, we are exempt from the requirement to respond to such requests. Please note that our brands are part of Whirlpool and are not third parties for purposes of this Privacy Notice. If you have any questions related to our policy, please contact us using the information provided in the “Contact Us” section below.
V. Data Security
We are committed to maintaining the security of the data you provide to us. We use reasonable organizational, technical, and administrative measures designed to protect Personal Information that we maintain within our organization. We also seek to use third-party service providers capable of protecting the information they maintain or process for us. Unfortunately, no data transmission over the internet or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below. Your Personal Information will be stored on FOTILE’s servers located at our global headquarters in Ningbo, China and/or at other third party facilities with which we have contracted for specific services.
VI. Third Party Services
VII. Use By Children
Our Websites are not directed to children under the age of 13. We do not seek to, nor do we knowingly collect, information from children under the age of 13, and we request that such individuals do not provide Personal Information through our Websites.
X. CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at email@example.com or please write to us at the following address:
FOTILE America LLC
6 Campus Dr Suite 210,
Parsippany, NJ 07054
We will respond to general privacy inquiries within 30 days. Opt-out requests will be processed within 10 business days.