WD-40 PRIVACY & COOKIES STATEMENT
Effective date: November 27, 2019
What this Statement Covers
This Statement describes how we use the personal information we collect from, or which is supplied to us, by visitors to the Website, including personal information we obtain when we offer services through the Website (the “Services”). You may only use our Services if you are over 16.
We provide this Statement because you have the right to know what information we collect about you, how it is protected and used, and the circumstances under which it will be disclosed.
- Information We Collect
- How We Use Your Information
- Sharing and Disclosing Your Information
- Marketing Communications
- Links to Other Sites
- Your Uploaded Content
- Retention of Information
- Your Rights
- Do Not Track Disclosure
- Social Media Features
- Social Media, Reviews, and Testimonials
- International Data Transfers-EU-US Privacy Shield
- How to Update Your Information
- Contact Information
- Changes to this Statement
1. Information We Collect
This Statement explains how we use personal information that we collect from, or which is supplied to us, by users of our Website.
We collect and process personal information about you when you interact with us and our Website, and when you purchase goods from us and/or use our Services. This information may include:
- Your name
- Your gender
- Your age/date of birth
- Your marital status
- Your company, job title and occupation
- Your hobbies/interests
- Your email address and phone number
- Your postal address
- Your payment information
- Content you provide including photos, audio and/or video (“end user content”)
- Your marketing preferences, including any consents you have given us
- Information related to the browser or device you use to access the Website
(collectively, “Personal Data”).
We use data about users to compile anonymous, aggregated statistics for operational and marketing purposes. Such purposes include benchmarking, determining appropriate levels of hardware, determining the numbers of employees needed to provide the Services to our users, and reporting numbers of users that use the Services. This anonymous, aggregated data is not used in any way that can identify an individual user.
We may receive information about your location from your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices provide users with the ability to turn off or disable location services. Most likely, these controls are located in the device's settings menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or your device manufacturer.
2. How We Use Your Information
We use the information you provide to us for the following purposes:
- As required by us to conduct our business and pursue our legitimate interests in particular:
- To respond to your inquiries
- To support your participation in promotions, competitions, sweepstakes and surveys and to administer these activities
- To provide embedded social media services
- To assist us in providing better products and Services: for example, to evaluate the performance of our staff, to assess the quality of our products and Services and to help us improve our Website, facilities and Services;
- To ensure the security of our Website and information technology systems
- To protect our rights and/or property or the rights and/or property of a third-party;
- To communicate with you about our products and/or Services
- To customize the online ads, special promotions, e-mails, and other marketing information you encounter to align with your interests
- To send you periodic customer satisfaction, market research or quality assurance surveys
- In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation)
- To have third-parties check the validity of the sort code, account number and card number of any credit or debit card that you provide as payment to prevent fraud
- When we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person;
- Where you give us your consent:
- We will send you direct marketing in relation to our relevant products and Services, or other products and services provided by us, our affiliates and carefully selected partners. If you want to stop receiving marketing materials from us, please tell us. Section 4 of this Statement explains how you can do this.
- We place cookies and use similar technologies and will do this in accordance with the cookie section of this Statement and the information provided to you when those technologies are used
- On other occasions where we ask you for consent, we will use the information for the purpose which we explain at the time
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation
- To fulfill a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or enter a promotion, competition and/or sweepstakes. This includes:
- Fulfilling your orders and taking payments from you
- Providing customer service related to your interactions with us or to respond to your enquiry
- Arranging the delivery or other provision of products, Services or prizes
3. Sharing and Disclosing Your Information
We share your personal information within WD-40 Company which is involved in carrying out the processing described above. We may use personal information relating to you to customize the advertising and marketing messages you receive on the Website or may work with outside companies to do so. Aggregated data may be shared with these companies so that this customization can be achieved. Anonymous click streams, number of page views calculated by pixel tags and aggregated demographic information will also be shared with our advertisers and business partners.
We also use data regarding your visit to the Website to perform statistical analysis to measure interest in, and use of, the various areas of the Website. We share such information with relevant advertisers or external parties. We will, however, provide only aggregated data from these analyses to third parties, not specific users' data.
Personal information will be shared with third-party service providers (including technology consultants and CRM vendors), who, in the course of providing services to us, will be given access to the information you have provided to us and will process it on behalf of WD-40 Company for the purposes identified above. Such third parties include providers of website hosting, maintenance, and technology and CRM services. Each of these service providers is contractually obliged to provide services to us in a manner consistent with this Statement.
Our employees, agents and contractors must have a business reason to obtain access to your personal information. We also share your personal information with those who help us manage or provide the Services (e.g. statistical analyses, data processing, and order fulfilment), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfillment aspects of promotions, competitions and sweepstakes. These outside contractors or agents will only use your personal information to provide us with a specific service and not for any other purpose.
When your personal information is shared with authorized third-parties, WD-40 Company will execute any needed contracts, clauses, or addendums to ensure such third-parties do so in a manner that is consistent with this Statement and Privacy Shield Principles.
If, in the future, we wish to share your personal information with third parties acting other than as our agents or service providers, we will tell you about this and provide you with the opportunity to opt-out.
If the business is sold, integrated with and/or transferred to another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Your personal information will be disclosed where disclosure is necessary for us to comply with a legal obligation or is otherwise necessary for us to protect our rights, the rights of our affiliated companies, the rights or safety of any individual or the public, and the rights of our users or any third-party.
4. Marketing Communications
From time to time, we would like to send you by email information about other similar WD-40 Company products or services which we think will be of interest to you (including, for example, newsletters and promotional communications). We will do this only if you agree and you have a right to object to receiving this information from us, or profiling we carry out for direct marketing, at any time. You can do this by:
- Following the opt-out instructions included in each email communication we send you; or
- Contacting us using the contact details set forth in Section 17.
We have implemented reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure.
We follow generally accepted industry standards to protect personal information submitted to us by users, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is 100% secure; therefore, we cannot guarantee its absolute security.
There are two types of cookies: session and persistent. Session cookies disappear from your computer when you close your web browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. You can remove persistent cookies by following directions provided in your internet browser’s “help” file. If you have chosen to identify yourself to us, then we use session cookies containing encrypted information to allow us to uniquely identify you.
We use persistent cookies that only we can read and use to identify browsers that have previously visited the Website. When users provide us with identifiable information about themselves, a unique identifier is assigned to them. This unique identifier is associated with a persistent cookie we place on the user’s web browser. We are very careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies.
If you want to delete cookies on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website.
To find out more about cookies please visit: www.allaboutcookies.org.
We use the following cookies:
Strictly Necessary Cookies
These cookies are essential to enable you to move around the Website and use its features. Without these cookies, services you have asked for, such as remembering your login details or shopping basket items, cannot be provided.
These cookies collect anonymous information on how people use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
These cookies remember choices you make such as the country you visit our Website from, language and search parameters such as size, color or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
Social Media Cookies
These cookies allow you to share what you have been doing on the Website as well as social media such as Facebook, Instagram, and Twitter. Cookies used by social media websites are not within our control. Please refer to the respective privacy policies of these sites to understand how their cookies work.
As is true of most websites, we gather certain information automatically and store it in log files. This information does not identify individual users. Log files include internet protocol (“IP”) addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Website, to see how users move around the Website, and to gather demographic information about our user base. We do not link this automatically-collected data to your personal information. We collect certain anonymous information from your visit to the Website via industry standard and commercially available web analytics solutions, such as Google Analytics and Matomo.
Clear Gifs (Web Beacons)
We use clear gifs (a.k.a. web beacons) to better manage content on the Website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the full-stop at the end of this sentence. We do not link the information gathered by clear gifs to users' personal information. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see Section 4.
Third-party applications (such as widgets) created by third-party developers may also be available on our Website. Third-party applications are small bits of software, often with interactivity, that can be installed into users' profiles or shared with other users. WD-40 Company does not control the third-party developers and cannot dictate their actions. When a user engages with a third-party application, that user is interacting with the third-party developer, not with WD-40 Company. We encourage you to review the privacy policies of the third-party, so you can understand how it collects, uses and shares information you choose to provide.
7. Links to Other Sites
The Website contains links to other websites over which we have no control. We are not responsible for privacy policies and/or practices of other websites to which you choose to link from this site. Please remember that when you use a link to go from our Website to another website, this Statement does not apply to the third-party website or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our Website, are subject to that third-party’s own rules and policies. We encourage you to review the privacy policies of those other websites, so you can understand how they collect, use and share your information.
8. Your Uploaded Content
You should be aware that if you provide comments, ideas, suggestions, testimonials, photographs, audio, videos, product reviews, product uses and potential uses, product ideas, feedback, end user content, or other information about you, the Website, the Services, our products, or any other content that we identify as relevant to our business interests (collectively, "Submissions"), to us either directly or on the Website or through the Services, we may use the Submissions, together with your name, initials, social media handle, or user name for our commercial and/or marketing purposes without acknowledgment or compensation to you.
9. Retention of Information
Where we process personal information for marketing purposes or with your consent, we process the data for the purposes outlined in this Statement unless a longer retention is required or permitted by law.
10. Your Rights
You have a right to ask us for a copy of your personal information. You also have the right to ask us to correct, delete or restrict (stop any active) processing of your personal data, and to obtain the personal data you provide to us for a contract or with your consent in a structured, commonly used and machine readable form, and to ask us to share (port) this data to another data controller.
You have the right to object to the processing of your personal information by us in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person or breach the privacy rights of others, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the contact details set forth in Section 17. If you have unresolved concerns, you have the right to make a complaint to the data protection supervisory authority where you live, work or where you believe a breach may have occurred.
You do not have to supply us with any personal information to visit the Website. If you use our Services we will ask you to supply us with information. When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the services you wish to access and whether the supply of any information we ask for is optional. If you choose not to provide the information, you may not be able to use some Services.
11. Do Not Track Disclosure
Currently, various browsers including Internet Explorer, Firefox, and Safari offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites visited by the user about the user's browser DNT preference setting. Although we do our best to honor the privacy preferences of our visitors, we are not currently able to respond to Do Not Track signals from your browser.
Our Services and Website are not designed to attract individuals under the age of 13. In accordance with the Children’s Online Privacy Protection Act (COPPA), we do not collect or store any personal information, even in aggregate, about children under the age of 13. If we discover we have received any information from a child under the age of 13 we will delete that information immediately. If you believe that we have any information from or about anyone under the age of 13, please contact us at the contact points specified below.
13. Social Media Features
Our Website may use social media features, such as the Facebook “Like” button and other widgets (“Social Media Features”). These Social Media Features may collect your IP address and which page you are visiting on the Website and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on our Website, WD-40 Company, our Services, or our products to a profile page of yours or ours that is provided by a third-party social media network to share with others within your network. Social Media Features are either hosted by a third-party or hosted directly on our Website. Your interactions with these features are governed by the privacy statement of the company providing the relevant Social Media Features.
14. Social Media Features, Reviews, and Testimonials
If you provide to us directly, choose to post on the portions of the Website that are viewable by others, or choose to post on social media any comments, ideas, suggestions, testimonials, photographs, audio, videos, product reviews, product uses and potential uses, product ideas, feedback, end user content, or other information (the “Postings”) referring or relating to WD-40 Company, our Website, our Services, and/or our products, we may use your Postings, social media user handle, profile picture, and name, for our commercial and/or marketing purposes without compensation or acknowledgment of any kind. Similarly if you tag WD-40 Company in any post or tweet on social media or use a hashtag referring or relating to us, our Website, our Services, and/or our products on social media, we may use, re-publish, and/or re-post your posts, tweets, social media handle, user name, profile picture, and name, for our commercial and/or marketing purposes without compensation or acknowledgment of any kind.
15. International Data Transfers-EU-US Privacy Shield
WD-40 Company complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. WD-40 Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, WD-40 Company is committed to resolve complaints about its collection or use of personal information in accordance with the Privacy Shield Principles. Residents of the EEA with inquiries or complaints regarding WD-40 Company’s Privacy Shield policy use or disclosure of Personal Data should first contact the Data Privacy Team at firstname.lastname@example.org. We will investigate and attempt to resolve complaints and disputes regarding the use or disclosure of Personal Data in accordance with the Privacy Shield Principles.
WD-40 Company has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If an EEA resident does not receive timely acknowledgment of a complaint from WD-40 Company, or if WD-40 Company does not address a complaint to the satisfaction of the complainant, the complainant may contact JAMS or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to the complainant.
As further explained in the Privacy Shield Principles, under certain circumstances, unresolved complaints regarding WD-40 Company’s obligations under the Privacy Shield Principles may be subject to binding arbitration before a Privacy Shield Panel in accordance with rules and procedures adopted by the U.S. Department of Commerce. Such binding arbitration is only available to resolve residual claims as to data covered by the EU-U.S. Privacy Shield.
Additionally, to foreign jurisdiction agencies having authority with respect to data privacy, WD-40 Company is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Notwithstanding any language to the contrary in this Statement, in cases of onward transfer to third parties of personal information of individuals received pursuant to the EU-US Privacy Shield, WD-40 Company is potentially liable in accordance with the Privacy Shield Principles.
16. How to Update Your Information
To change or update the information we hold, and which relates to you, please contact us using the contact details set forth in Section 17.
17. Contact Information
If you have any questions about this Statement, please contact us at email@example.com
18. Changes to this Statement
We reserve the right to modify this Statement at any time. If we make material changes to this Statement, we will notify you of this either by email or by means of a notice on the Website; where necessary we will obtain your consent. You can determine when this Statement was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to our Statement will become effective upon our posting of the revised Statement on the Website.