Freudenberg Household Products

Effective Date: [insert date of posting]
Last Updated: [insert date]

ABOUT THIS PRIVACY POLICY

Thank you for visiting the Vileda website. This Privacy Policy describes our data and privacy practices for data collected by Freudenberg Home and Cleaning Solutions GmbH and its affiliates, including Freudenberg Household Products (collectively, “FHP”) through our website, www.vileda.ca, and any other website, product, feature, or service we offer that posts or provides a valid link to this Policy (collectively, the “Site”). This Site is directed to users in Canada.

By accessing, using, or otherwise interacting with the Site or submitting information to us, you are accepting and consent to the practices described in this Privacy Policy. Please also review our Terms of Use, which also applies to your use of the Site. If you do not agree to the Terms of Use or consent to have your personal information processed in accordance with the Privacy Policy, please do not use the Site or provide personal information to us.

There may be times when you are interacting with us when we provide additional information or ask your consent for certain data processing. These additional disclosures supplement this policy and will apply to that feature or functionality.

If you have any questions about this Policy, including if you wish to send us a request to exercise any legal rights you may have, please contact us at the information provided in the Contact Us section below.

Table of Contents

1. How We Collect Information
2. How Do We Share the Personal Information We Collect?
3. Third Party Advertising and Analytics
4. Your Choices and Privacy Rights
5. Third Party Links and Content
6. Security
7. General Audience Site
8. Processing Outside of Canada
9. Changes to Privacy Policy
10. Contact Us
11. How Long Does FHP Retain Information About Me?
12. Data Governance

Types of Personal and Non-Personal Information We Collect and When, How We Use It, and How We Share It

We and third parties we work with (including service providers) collect information directly from you, from third parties, or automatically when you visit the Site through cookies and similar technologies. Some of the data we collect is personal information, which we consider to be data that is linked to a specific, identifiable individual (such as your full name and email address). We will treat other information, such as IP addresses and cookie identifiers, as personal information or sensitive data where required by applicable law. Note that, where permitted by applicable laws, we may de-identify or pseudonymize personal information to make it non-personal, either by combining information of numerous consumers or transforming it in such a way that the information can no longer be linked to a particular consumer or their household, such as by hashing the data or otherwise removing characteristics that make the data personally identifiable to you.

We will treat de-identified or pseudonymized data as non-personal to the fullest extent allowed by applicable law. We are committed to maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements.

The following chart sets out by category the personal information collected (“Category”), the purposes for which the information is collected (“Purposes”), the categories of third parties to whom the information may be disclosed for a business purpose (“Disclosed To”), and the categories of third parties to whom the information may be sold for monetary value or other valuable consideration or shared for cross context behavioral advertising/targeted marketing (“Sold/Shared To”).

For more information about certain practices disclosed in the chart, please also see Additional Details About our Data Practices.
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Information You Provide Directly
User Content and Submission Features. The Site may permit you to submit or post photos, audio, video, text, files, social media posts, or other content (“User Content”) through interactive or other features, such as product reviews, comments, posts, or promotional activities (“Submission Features”). Your submission of User Content is subject to the Terms of Use for the Site which give us the right to use your User Content, online or offline, in connection with our promotional activities. Personal information, such as your name, user name (from the Site or your social media account), or where you reside, may be publicly displayed with your User Content. Others may access it, use it, and share it. We are not responsible for how others use User Content you submit or post. In addition, in connection with certain activities, your personal information may be disclosed publicly, for example, being identified as a winner of a sweepstakes or being awarded a prize.

Sweepstakes, Contests, Promotions. We may offer sweepstakes, contests, or other promotions (any, a "Promotion"), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may require specific requirements of you (including, without limitation, and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list). Your personal information may also be shared with the public (including photos and videos on social media channels and other publications) in connection with announcing winners.

Information We Collect Automatically When You Access or Use the Site
We and our third party business partners (including service providers or content, advertising, and analytics providers) may use a variety of technologies, including cookies and pixel tags, that collect certain information automatically or passively from the computer, phone, or other device you use whenever you access, use, or otherwise interact with the Site (“Device ID/Interaction Information”).

Device ID/Interaction Information may include, but is not limited to: your Internet protocol (IP) address, mobile device identifier or other unique identifier, device information (including model, browser type, and operating system, device date and time, mobile network information), and how you use and interact with the Site (including time and date you visit, search terms, the pages you access and content you view, and the address of the page that directed you to our Site). We use this data to understand patterns of Site activity and to improve the Site so it is more useful for you. We also use third party advertising and analytics providers, which are described in more detail at the Third Party Advertising and Analytics section below.

Device ID/Interaction Information may be collected by us or third parties through the following technologies:
Cookies and Local Storage. Cookies and Local Storage are text files placed within a browser on a device when it is used to access the Site and record small amounts of data. Certain web browsers and browser add-ons may provide additional local data storage mechanisms. These serve various purposes, including making our site work properly and optimizing your experience. We and third parties may use cookies and similar technologies to help keep your use of the Site more secure, to study traffic patterns on the Site, to study the effectiveness of our customer communications, to maintain the integrity of the Site, to measure crash analytics and other maintenance related data, to manage and measure the performance of advertisements displayed on or delivered by or through the Site, and to personalize your experience on the Site, such as to recognize you when you return to the Site. Most browsers provide you with the ability to disable, decline, or clear cookies and local storage; please check your browser’s settings for further information. However, if you disable cookies, you may find this affects your ability to use certain parts of the Site. For more information about cookies, please visit https://www.aboutcookies.org. The cookies we use – and how to control them – are listed in our Cookies Policy.

Pixel Tags. Small graphic images or other web programming code (also known as web beacons or pixel tags or 1x1 GIFs or clear GIFs) may be included in our web pages and email messages. These and similar technologies may be used for a number of purposes by us and our third-party providers, including to count visitors to the Site, to monitor how users navigate the Site, to count how many of our email messages were opened, or to count how many particular products were viewed, or for marketing and targeted advertising purposes. The data we collect through this technology may include the first date and time you open our email, and whether you click any links included in our email.

Embedded Scripts. An embedded script is programming code that is designed to collect data about your interactions with the Site, such as the links you click on. The code is temporarily used by our server or third party service provider or business partner while you browse or interact with the Site and is deactivated or deleted when you disconnect from the Site. Session Replay Technology. We may record through session replay technology your interactions with the Site, such as what pages you visit on the Site, how long you visit those pages, and any links you click or data you provide. We use this data for our internal business purposes, such as for website analytics, to improve the Site and our products and services, and to address functionality issues.

In addition, we may use a variety of other technologies that collect similar data for security, fraud detection, and maintenance purposes.

Information We Receive or Collect from Third Parties
Enhancement Data. Where permitted by law, we may receive data about you from other third parties, such as data aggregators, joint marketing partners, third party websites, service providers and other business partners. We may also supplement the data we collect with outside records from third parties, such as public databases, publicly available social media pages, and third parties who enhance the data we have about you, in order to provide you with information or services you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes. The data collected and stored by third parties is subject solely to the third party’s privacy practices.

We may share the information (including personal information) we have collected about you as disclosed in the chart above and in the circumstances described below or elsewhere in this Privacy Policy, as disclosed at the time you provide information, or otherwise with your consent.

Non-Identifiable Data. Except as expressly prohibited by applicable law, we may share non-personal and non-identifiable information, including Device ID/Interaction Information, hashed or otherwise de-identified or pseudonymized data, and aggregated user statistics, with third parties in our discretion, including for targeted advertising purposes.

Parent/Subsidiaries/Affiliates. We operate under a corporate parent and with other affiliated brands and companies, some of which operate as subsidiaries or affiliates. You can see our family of brands here. When we collect data through the Site, it will be accessible across our family of brands and companies. These companies process the data to assist us in carrying out our business and operational purposes identified above.

Service Providers/Vendors. We share information with third party vendors who perform services on our behalf. This includes website hosting companies, public relations companies, advertising and marketing agencies, and mail delivery service companies.

Third Party Advertising and Analytics Partners. As fully described in the Third Party Advertising and Analytics section, we share (or allow third parties to collect) certain data, including about how you use the Site, to target advertising to you and others and assess the effectiveness of our advertising, and for similar purposes.

Social Media and Other Third-Party Platforms. You may be able to use the Site to interact with social media or other third-party platforms, like Instagram and Spotify. When you interact with these third-party platforms through the Site, we will receive data about you from the third-party platform service and you will be choosing to share data about your interactions with FHP with that social media service.

In addition, the third-party platform service may set their own cookies and collect data about your use of the Site, including your IP address or other device identifiers, and which pages you visit on the Site. These third-party platforms may be able to collect certain data on your visits to the Site regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the third-party platform. If you are logged out or do not have an account and visit a page with a social plug-in, your browser sends a more limited set of data. Like other sites, the third-party platform will receive data about the webpage you are visiting, the date and time of your visit, and other browser-related data. They may use that data to help them improve their products or for other purposes set forth in their privacy policy. We may also receive data about you if other users of social media give us access to their profiles and you are one of their connections or "friends."

The data we collect is subject to this Privacy Policy. The data collected and stored by the third party remains subject to the third party’s privacy practices, including, without limitation, whether the third party continues to share data with us, the types of data shared, and your choices with regard to what is visible to others on that third-party website or service. The third party may allow you to remove the application or feature, in which case we will no longer collect data about you through the application or feature, but may retain the data previously collected.

If you choose to post information to a third-party platform, that information may be made publicly available. We recommend that you review the privacy policy of the social media platforms or third-party platforms before sharing any personal information.

Third Parties to Whom You Agree or Direct Us to Share Your Data. We may share your personal information when you consent or otherwise direct us to do so. For example, if you engage with a third-party social media application or other feature through which data is shared or if you consent to have your data shared in connection with a Promotion we run with a third party.

Information You Disclose Publicly. When you choose to submit product reviews or other content that will be posted on the Site please remember it becomes publicly available, and you should think carefully before you post and exercise caution when deciding to disclose your personal information.

Third Parties for Legal/Administrative Purposes. We also reserve the right to use or disclose personal information as needed (i) when we are under legal compulsion to do so (e.g., we have received a subpoena) or we otherwise believe that the law requires us to do so, including to cooperate in any law enforcement investigation, an investigation on a public safety matter, or an investigation into claims in intellectual property infringement; (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or safety of FHP, our users or others; or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud, and otherwise enforce this Privacy Policy and any applicable Terms of Use for our Site. We may also use device identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies, in our discretion.

Third Parties in Connection with Business Transfers. Additionally, in the event that FHP is merged with or becomes part of another organization, or in the event that FHP is sold or it sells all or substantially all of its assets or is otherwise reorganized, the information you provide will be one of the transferred assets to the acquiring or reorganized entity. We may also transfer personal information to third parties where we are expressly authorized by applicable law to do so (including, without limitation, during the course of any due diligence process). By providing your data, you understand and agree that we may transfer such data to the acquiring entity or reorganized entity without your further consent, except where required by law.

We may use third party business partners, such as analytics companies, ad agencies, network advertisers, and others who provide us with data about the Site, users, and our advertisements, and who deliver ads to you on our behalf on the Site and elsewhere online. We and our third-party business partners collect certain data about your visits to and activity on the Site and other websites and services, including as described in “Third Party Advertising and Analytics”, and may use this data to target advertising to you and others and to assess the effectiveness of our advertising. We may also share (or permit third parties to collect) certain data, such as Device ID/Interaction Information, aggregated or de-identified, pseudonymized or hashed data (including email addresses), with these third parties for similar purposes.

These third parties may set and access their own tracking technologies on your device (including cookies, web beacons or other technology) and may otherwise collect or have access to your personal information over time, including about your visits to the Site as well as other websites and online services, some of which may be personal information. Companies that we share data with, including ad agencies and networks, may use the data, often in combination with their existing data, in order to present more relevant advertisements that may be of interest to you, and to help us and third parties to do the same.

• Cookie Opt-Out. To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please adjust your settings by clicking here.
   
• NAI/DAA Opt-Out. Some of the companies we use may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). The NAI provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt-out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit the DAA's website, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. You may also learn about interest-based advertisements from participating third parties in Canada at the Canadian DAA choice page at http://youradchoices.ca/choices/.
   
• GPC. Global Privacy Controls (GPC) offered by some web browsers are settings that automatically inform websites of your privacy preferences with regard to third party online tracking including exercising your rights and requesting the web application to disable tracking you for certain purposes. When you choose to turn on the GPC setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to exercise your privacy rights and stop tracking your activity for certain purposes. You can learn more about and set up GPC here.
   
• Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze data about the use of the Site and report on activities and trends. This service may also collect data about the use of other websites, apps, and online services. You can learn about Google's practices, and opt out of them by downloading the Google Analytics opt-out browser add-on.
   
• Microsoft Clarity. Clarity enables us in making data-driven decisions on what works and what doesn’t. Clarity captures the interactions on our website such as how the page has rendered and what interactions users undertake such as mouse movements, clicks, scrolls. Clarity uses marketing cookies to track visitors across our website. When the script is installed, Clarity’s cookies send anonymous and non-personally identifiable information about website users. Clarity is a user behavior analytics tool that helps us understand how users interact with our website. Clarity is GDPR-compliant as a data controller. For more information, see the Microsoft Privacy Statement: https://privacy.microsoft.com/privacystatement and https://docs.microsoft.com/en-us/clarity/cookie-consent. You can opt out of Microsoft Clarity cookies by clicking on cookie settings and preferences here.

Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online. Your opt-out choices are browser and device specific; if you disable your cookies, upgrade your browser after opting out or if you use multiple different devices, please opt-out on each device and each browser separately.

• Withdrawing Consent. Where we rely on consent to process your personal information, you may withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice).
   
• Marketing Emails. Where required by applicable law, we will obtain your consent before sending you marketing or promotional emails. You can opt out of receiving future marketing/promotional electronic mailings from us by following the unsubscribe procedures indicated in each electronic mailing, such as “unsubscribe” or “manage your preferences." Please note that opting out of receiving marketing or advertising emails from us will not apply to transactional communications or notices, for example, emails in response to your requests or changes to our terms or policies.
   
• Updating Your Information. You are responsible for maintaining the accuracy of the data you submit to us, such as your contact data. If you wish to update the data you have provided to us, please Contact Us. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. Note, however, that data may persist internally for administrative purposes and that residual data may remain on backup media or for other reasons.
   
• Your Privacy Rights. If you would like to submit a request to access, correct, or update, obtain a portable copy, or withdraw consent to the continued processing of your personal information, you must submit your request to us at the information provided in the Contact Us section below. You may be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request.

The Site may contain content that is served by someone else or links to third-party content, applications, or websites. We do not control this content or these sites. The third-party operators and content providers use their own cookies or other tracking technologies, and they may independently collect information from or about you. We are not responsible for the privacy practices employed by any third party.

We use commercially reasonable steps designed to secure your personal information; however no data transmission over the Internet, wireless transmission, or electronic storage of data can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any data we collect. You use the Site and provide us your data at your own risk.

The Site is general audience and does not target users younger than the age of 18. We do not knowingly collect personal information online from children younger than the age of 18. If you are a parent or guardian and think we have data about your child, please contact us as set out in the Contact Us section below.

Please be aware that the data we collect may be communicated outside of Canada (and outside of Quebec if you are located in Quebec), including to the United States and other countries. This data may therefore be subject to access requests from governments, courts, or law enforcement in foreign countries according to the laws in those countries. If you have any questions, would like to receive further written information about our policies and practices regarding third parties outside of Canada, please contact us as set out in the Contact Us section below.

We reserve the right to make changes to or modify this Policy in our discretion at any time and may apply any changes to information previously collected, as permitted by applicable law. When we make material changes to this Policy, we will notify you by posting the updated Policy on our Site, update the effective data at the top of this Policy prior to the change becoming effective, and take other steps to the extent required by applicable law, such as contacting you through contact information you have provided. We will provide notice and obtain your consent to the new policy, which may be opt-in or opt-out consent, if required, or which may occur your continued use of the Site, to the fullest extent allowed by applicable law.

We welcome your questions, comments and concerns about privacy. FHP is committed to the resolution of concerns about your privacy and our collection or use of your personal information. If you have any questions, concerns, or complaints regarding this Privacy Policy or how we protect your personal information, please contact us at:

Freudenberg Household Products
Attn: Consumer Affairs/Privacy Office
2188 Diehl Road
Aurora, IL 60502
1.800.543.8105
privacy@ocedar.com
4832-3571-0894.4

Your request or complaint should include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding your request. Please also include “Vileda” in the subject line of your request. We may need to verify your identity before complying with your request.

We will retain all categories of Personal Information described above for as long as reasonably necessary to fulfill the purpose for which it was collected, allow you to exercise the choices and rights you requested, comply with our contractual obligations, enforce our policies, or as required by applicable laws or regulations.

Our Data Protection Officer is in charge of the protection of personal information. This includes developing and delivering privacy training to relevant personnel, establishing and publishing relevant policies and procedures, investigating and responding to complaints and potential violations of our privacy policies or relevant laws, responding to requests from individuals to exercise their rights under applicable privacy laws, and regularly reviewing and identifying opportunities to improve our privacy program. You may contact our Data Protection Officer at Eileen.Kaser@fhp-ww.com or +1 630-270-1420.

Our Global Director Governance, Risk Management and Compliance is responsible for managing our information security program, assisting with breach prevention, response and containment, and evaluating and implementing information security controls.

Within our organization, personal information may be handled by various personnel who need to access the information in order to perform their duties. These personnel include sales, marketing, finance, IT, security. All FHP personnel handling personal information will be subject to a duty of confidentiality and policies and practices to ensure that all personal information is handled in accordance with applicable laws.