Connected Appliance Privacy Policy
Last Updated / Effective Date: January 11, 2024
Sub-Zero Group, Inc. is committed to protecting the privacy of our customers. This Connected Appliance Privacy Policy (“Connected Privacy Policy”) provides information about how we collect, use, share, retain, and safeguard your Personal Information when you use our Connected Appliance Services (the “Services”) and our related Sub-Zero Group Owner’s App (the “Mobile App”) to utilize the interactive functions of your Sub-Zero Connected Appliance.
If you are using our website or our Sub-Zero Spec App, the Sub-Zero Privacy Policy applies instead of this Connected Privacy Policy.
IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 11 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.
IF YOU ARE A CANADIAN RESIDENT, PLEASE SEE SECTION 12 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.
1. WHAT IS PERSONAL INFORMATION?
For purposes of this Connected Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information excludes publicly available information, aggregated or deidentified consumer information, or information which is otherwise excluded under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and their implementing regulations (“CCPA”).
2. PERSONAL INFORMATION WE COLLECT
We collect the following categories of Personal Information when you use the Services or the Mobile App. We have provided examples of the types of data collected in each category and information about how long we keep that data:
We collect the following categories of Personal Information:
| Category of Data | Examples | Retention Period |
|---|---|---|
| Identifiers | Name, email address, mailing address, postal code, phone number, IP address, unique personal identifiers, and device name. | We retain Identifiers as long as we have a business relationship with you, which may extend through the life of our products. |
| Commercial Information | Connected Appliance purchases (including replenishments), purchasing history (and related contact information), and invoices. | We retain this information as long as we have a business relationship with you, which may extend through the life of our products. |
| Geolocation Information | Imprecise location information such as your IP address and precise geolocation information concerning the location of your appliances. Precise geolocation information concerning the location of your appliances. Time Zone |
For so long as required for our business purposes. |
| Sensory Information | Voice recordings of your calls to customer service. | We retain recorded call-center calls for 30 days. |
3. THE PURPOSE FOR WHICH WE COLLECT THE INFORMATION & THE SOURCE
We collect Personal Information directly from you when you create an account, communicate with us or otherwise provide your information to us, as further described in the table below.
| Purpose of Collection and Use | Examples/Explanations | Category |
|---|---|---|
| To Communicate with You | To communicate with you about the features of your Connected Appliance and your Mobile App account (including service and warranty information); To respond to your questions, requests or concerns; To advise you of change to this Connected Privacy Policy; To send notifications to you including notifications regarding your appliances; To provide updates, text messages, push notifications, email alerts, including notifications of faults, product alerts, and end of cycle signals; and To contact you if we receive a service notification for your registered Connected Appliance, or to issue other notices concerning the safety of your Connected Appliance. |
Identifiers |
| Account Creation and Maintenance | To enable you to create and manage your customer accounts and assist you with your accounts and your use of our Services and the Mobile App; and To assist with resetting passwords and other needs for you to use the Services and the Mobile App. |
Identifiers Commercial Information |
| Customer Care and Support | To provide you with customer care and support in connection with the purchase, delivery, installation, maintenance, service or repair of your Connected Appliance; To facilitate warranty registration; and To improve customer satisfaction. |
Identifiers Commercial Information |
| Business Purposes | To improve our Connected Appliances, the Services and the Mobile App; To engage in product research and development; and To engage in business transactions. |
Identifiers Commercial Information |
| Marketing and Advertising | To send you newsletters and other electronic correspondence notifying you of new Connected Appliance products, services and promotions; and To market to you and to engage in advertising. |
Identifiers Commercial Information |
| Mobile App and Services Management | To troubleshoot problems; To protect the security of the Mobile App; To perform statistical and other analyses of the Services and the Mobile App; and To customize the Services and the Mobile App to you and our users. |
Identifiers Commercial Information |
| For Compliance and Legal Purposes | To protect our legal rights or interests, or those of third parties; To bring a legal action when necessary to protect legal rights; To respond to California privacy rights requests; To respond to other legal requests; and To enforce violations of our Terms of Use. |
Identifiers Commercial Information |
| Identifying Your Region | We may use geolocation information from the device you use to access the Mobile App to set the time-zone on your Connected Appliance. | Geolocation Information |
Information we collect from third-party sources and your Connected Appliance
We may obtain data from various third-party companies and public sources. We may combine that data with Personal Information or other data we collect.
Additionally, your Connected Appliance is equipped with electronic sensors that permit a two way exchange of data between the Connected Appliance and our computer system. This collection occurs automatically via our computer system, on a continuing basis. We collect and store the electronic data we receive from your Connected Appliance or from the electronic devices (such as cell phones, computers and tablets) you use to access the Services or the Mobile App ("Connected Data"). Some Connected Data may be considered Personal Information under certain laws.
| Purpose and Use | Examples | Category of Information |
|---|---|---|
| Connecting Third Party Devices | If you decide to connect your Connected Appliance to a third-party device or product to utilize that functionality of your Connected Appliance ("Third-Party Device"), we may receive Personal Information and Connected Data from that provider. Examples of such third-party Devices include without limitation any type of smart home hub device, specifically an Alexa-enabled device (e.g., Amazon Echo), Google Home device, or a Nest security system. | Identifiers |
4. SHARING PERSONAL INFORMATION
We disclose or share Personal Information with third parties for the following purposes:
| With Whom We Share Personal Information | Purpose | Category of Information |
|---|---|---|
| Subsidiaries, Affiliates, Distributors, and Dealers | We may disclose or share your Personal Information for our Business Purposes, including to facilitate a purchase and to service your products. | Identifiers Commercial Information |
| Third Party Device Providers | If you decide to connect your Connected Appliance to a Third-Party Device, we may share information with them to facilitate that connection. Please review the Third-Party Device provider’s privacy policy to learn more about their privacy practices. | Identifiers |
| Government Officials and Law Enforcement | To comply with legal requirements, as ordered by a court or if we believe in good faith that the law requires it; and To identify, contact, or bring a legal action against someone who may cause or be causing harm to you, us, our employees or other third parties, including anyone interfering with your appliances or our information technology systems. |
Identifiers Commercial Information |
| Service Providers | We may share your Personal Information with the following types of service providers, in accordance with contractual provisions that require them to protect your Personal Information, as follows: Customer Service: To sell, install, deliver, maintain, and service your Connected Appliances. Mobile App Management: To operate and manage the Mobile App; to improve Mobile App content and functionality; and to support or provide the security of Services and the Mobile App. Hosting: To host the Mobile App. IT Services: To provide IT and software development services. Marketing and Communications: To provide email services on our behalf; respond to your questions or comments on our behalf. Other: We also share with service providers as indicated at the time and point of collection. |
Identifiers Commercial Information |
| Professional Advisors | We may share your Personal Information to receive advice from our professional advisors, such as our attorneys, accountants, financial advisors, marketing consultants, and business advisors, in their capacity as advisors to us. | Identifiers Commercial Information |
| Parties to Business Transactions | We may share your Personal Information in connection with a contemplated or completed business transaction such as a merger, acquisition, sale of all or substantially all of our assets or equity to a successor, subsequent owner or operator, a dissolution, bankruptcy, liquidation, or other similar business transaction where Personal Information may be shared, sold, or transferred to that third party, including during the due diligence process. | Identifiers Commercial Information |
5. USE AND DISCLOSURE OF DE-IDENTIFIED OR AGGREGATED INFORMATION
We may collect, use, share, transfer, and otherwise process Personal Information that we then de-identify, aggregate, or both so that your Personal Information is no longer identifiable. Once Personal Information has been de-identified and aggregated, it is no longer considered Personal Information under applicable laws, and we may use this information for any lawful purpose.
6. YOUR CHOICES
We recognize that you may want to limit how your Personal Information is used and shared. We currently offer the following choices and options:
- Opt-out of Marketing Communications. We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at [email protected] with "unsubscribe" in the subject line. To opt-out of other communications (e.g., postal marketing and telemarketing), please contact us as set forth in the "Contact Us" section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.
- Mobile Location Choices. If you use our App, you may decline to provide location information through your mobile device settings or any prompt requesting location information.
- For California Residents. If you are a California resident, you may opt out of the sale or sharing of your Personal Information by broadcasting an opt-out preference signal, such as the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Additionally, you may fill out the form here.
7. PROTECTION OF CHILDREN’S PERSONAL INFORMATION
We do not publish content that is targeted to children. We do not intend for children under the age of 16 to use the Services or the Mobile App. We do not knowingly collect, maintain, or disclose a child's Personal Information. If you are under 16, you should not send any Personal Information about yourself to us.
If you are a parent or guardian who has discovered that your child under the age of 16 has submitted his or her Personal Information without your permission or consent, we will make reasonable efforts to remove the information from our database, at your written request. To request the removal of your child's information, please send an email to [email protected] and be sure to include the same information that your child submitted. For clarity, we do not sell the Personal Information of anyone under the age of 16 years old without affirmative authorization.
8. CHANGES TO POLICY
WE MAY, AT ANY TIME, REVISE THIS CONNECTED PRIVACY POLICY BY UPDATING THIS POSTING. IF WE MAKE A MATERIAL CHANGE TO THIS CONNECTED PRIVACY POLICY, WE WILL POST A NOTICE ON THE TOP OF THIS POLICY, ON OUR SITE OR NOTIFY YOU BY ANOTHER METHOD THAT WE HAVE MADE CHANGES TO THIS CONNECTED PRIVACY POLICY. ALL CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON POSTING.
9. CONSENT TO PROCESSING IN THE UNITED STATES
If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions, such as in Canada and the European Union.
10. THIRD PARTY LINKS
We are not responsible for any content offered on any third-party websites, devices or applications. Links to third-party websites or applications are provided for your convenience only. This Connected Privacy Policy will not apply to any Personal Information that you provide to, or that is collected by, any third-party website operator, third-party product or service provider, or Third-Party Device Provider. Other third-party services or applications, like your wireless data plan or phone provider, have their own privacy statements. Those third-party privacy policies have separate terms and should be read separately from this Connected Privacy Policy.
11. TERMS APPLICABLE TO CALIFORNIA RESIDENTS
This Section 11 provides additional terms that apply to residents of California. In the event of a conflict between this Section 11 and the remainder of this Connected Privacy Policy, this Section shall take precedence for California residents.
YOUR CALIFORNIA PRIVACY RIGHTS
Under the CCPA, California residents have certain additional privacy rights, subject to certain exceptions. If you live in California, you may exercise those California privacy rights listed below. Capitalized terms in this Section that are not defined elsewhere in this Connected Privacy Policy have the definitions set forth in the CCPA.
Categories of Personal Information We Have Collected. During the past 12 months, we have collected the categories of Personal Information listed above in the “Personal Information We Collect” Section.
Categories of Personal Information Disclosed for a Business Purpose. During the past 12 months, we have disclosed the following categories of Personal Information for a Business Purpose: Identifiers and Commercial Information.
Categories of Personal Information Sold or Shared. In the last 12 months we have not “Sold” or “Shared”, as defined under CCPA, Personal Information collected through the Mobile App.
We Do Not Use or Disclose Sensitive Information. We do not use or disclose sensitive information, as defined in the CCPA.
Your Rights
Right to Know. You have a right to request that we disclose certain information about you and our collection and use of your Personal Information over the last 12 months.
Once we receive your request and confirm your identity, we will disclose to you as required under the CCPA:
- The categories of Personal Information we collected from or about you;
- The categories of sources from which the Personal Information was collected;
- The Business or Commercial Purpose for collecting, sharing, or selling your Personal Information;
- The categories of Third Parties to which we have disclosed your Personal Information;
- The specific pieces of Personal Information we have collected about you;
- The categories of Personal Information that we sold, shared, or disclosed for a Business Purpose; and
- The categories of Third Parties to which that information was disclosed for a Business Purpose.
Right to Request Deletion. You have a right to request that we delete Personal Information we collected from or about you. We will comply with such requests and direct our service providers or third parties to do the same, subject to certain exceptions permitted by applicable law.
Right to Correct. You have the right to correct inaccurate Personal Information that we collect about you. If we receive a verifiable request, we will consider it, taking into account the nature of the Personal Information and the purposes for which we process the Personal Information. We may deny your request if we are unable to verify your identity or if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances. We may request that you provide us with documentation that is relevant to your request.
Please note, we may choose to delete the contested Personal Information as an alternative to correcting it, if doing so would not negatively impact you or with your consent.
Right to Data Portability. You have the right to request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Non-Discrimination. You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA.
Right to Limit the Use of Sensitive Personal Information. CCPA provides consumers with the right to request that we limit the use of your Sensitive Personal Information, as defined in that statute. We do not use any Sensitive Personal Information to make inferences about you.
If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.
How to Exercise Your California Privacy Rights. To exercise your rights under the CCPA, you may contact us at any of the following:
By Mail:
Sub-Zero Group, Inc.
Attn: General Counsel
4717 Hammersley Rd.
Madison, WI 53711
By Phone: +1-800-222-7820>
Visit our Website: https://www.subzero-wolf.com/assistance
Email us at: [email protected]
Who May Exercise Your Rights. If you are a California resident, only you or a person that you authorize to act on your behalf may make a request related to your Personal Information. See the section titled “Using an Authorized Agent” for more information. A parent or legal guardian may make a request on behalf of their child.
Verifiable Consumer Request. You must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
When we receive your request to exercise your rights under the CCPA, we will: (a) acknowledge receipt of your request; (b) try to match the information that you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (d) consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request and let you know why.
When We Will Respond To Your Request. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Using an Authorized Agent. You have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If you choose to use an authorized agent, you must (a) provide signed, written permission that authorizes the agent to submit requests on your behalf and (b) verify your identity directly with us or (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both you and the authorized agent.
We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
CALIFORNIA SHINE THE LIGHT.
Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us as set forth at the end of this Connected Privacy Policy to receive this information.
12. TERMS APPLICABLE TO CANADIAN RESIDENTS
Your Canadian Privacy Rights. Under Canadian privacy laws you have certain rights to access and correct Personal Information, including the right:
- To be informed of the existence, use and disclosure of your Personal Information;
- To receive an account of the uses that have been made of your Personal Information by us and any third parties to whom it has been disclosed;
- To be given access to your Personal Information; and
- To challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.
Please contact us using the information provided below in Section 13 to exercise your rights under Canadian privacy laws or for any other privacy-related complaints or inquiries. We may require that you provide information verifying your identity before we provide this requested information to you.
Legal Disclosures and Lawful Requests. We and our Canadian, U.S., and other foreign affiliates and relevant service providers may disclose your Personal Information in response to a search warrant, other legally valid inquiry or order, or as may otherwise be required or permitted by applicable law, which may include lawful access by U.S. or foreign courts, law enforcement, or other government authorities. We may also disclose your Personal Information to another organization in order to enforce our rights arising from any contracts we have entered into, including to investigate a breach of contract or violation or law, as well as to detect, suppress, or prevent fraud. Finally, we may disclose your Personal Information as necessary to establish, exercise, or defend against legal claims and to investigate or prevent actual or suspected loss or harm to people or property.
13. CONTACT US
If you have any questions or comments about this Connected Privacy Policy, please contact us at:
Sub-Zero Group, Inc.
Attn: General Counsel
4717 Hammersley Rd.
Madison, WI 53711
+1-800-222-7820
https://www.subzero-wolf.com/assistance
[email protected]