Last Updated: December 8, 2021
NOTICE REGARDING USE OF THE SERVICES BY CHILDREN
The Services are not directed to children under the age of eighteen (18), and we request that children do not provide personal information through the Services.
HOW WE COLLECT AND USE PERSONAL INFORMATION
We will collect personal information about you, such as your name, postal address, telephone and mobile numbers, email address, credit card number or other payment number, date of birth, gender, IP address, profile pictures, or social media IDs through your use of the Services, such as when you create an account or profile, order or register a product, order literature, enter contests or incentive programs, sign up for newsletters, download an App, participate in a survey, contact customer service, or otherwise interact with the Services. We may also receive your personal information from other sources, such as public data bases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms; as well as from other third parties. For example, if you elect to connect your social media account to your Site account, certain personal information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles.
We use your personal information to provide the services you request from Liberty Hardware such as responding to product information requests; registering products; fulfilling orders for parts, products or customer service; initiating refunds; administering contests or incentive programs; and facilitating on-line product visualization applications and preferred products catalogs. We also use personal information to send you news about our products and promotions, to conduct online surveys, contests, other similar promotions or incentive programs via email, telephone, or postal mail, and to notify you of special events and advertising that you might be interested in. Please see the “Sweepstakes, Contests, and Other Promotions” section below for more information on participating in such activities. Further, we may also use personal information to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important to your use of the Services, you may not opt-out of receiving such communications. In addition, we may use the information to improve Liberty Hardware online and other services, such as through customer service and product support, to understand consumer preferences in developing product improvements and innovations. We may also use your personal information for internal business purposes, such as optimizing users’ Services experiences and analyzing, managing, and expanding our businesses. If you apply for employment with Liberty Hardware, we may use the personal information you supply to process your job application.
The Services may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend. If you choose to use this feature, we will ask you for the recipient’s name and email address, along with the text of any message you choose to include. By using this feature, you are telling us that you are entitled and provide us with the recipient’s name and email address for this purpose.
HOW WE SHARE PERSONAL INFORMATION
Liberty Hardware may share personal information collected via the Services with Affiliated Entities or other third parties as described below. You should also be aware that personal information about you may be transferred to or received by Affiliated Entities or third parties in the U.S. or in other countries, which countries may have different privacy regulations than those applicable in the country where you reside.
- Service Providers. We may use third-party service providers to help us operate our business and the Servicesor to administer activities on our behalf, such as sending emails, hosting dealer locater sites, providing order fulfillment, conducting advertising or customer service, and administering contests or incentive programs. We may share personal information with these third parties for those business purposes. For instance, if you request a brochure, we may share personal information about you with fulfillment and management agencies to complete your request.
- Other Third Parties. We may share personal information with unaffiliated third parties, including dealers and retailers discussed above, to permit such third parties to send to you marketing materials. If you wish to opt-out from our sharing of your personal information with third parties for their marketing purposes, please see the “Choice: Opt‑Out” section below for information on how to opt-out.
- Emails to Friends. Please note that any personal information you provide in connection with sending an electronic postcard or other message to a friend through the Services, such as your name and your email address, will, of course, be disclosed to your friend.
- Promotions. We may share the personal information you provide in connection with sweepstakes, contests and similar promotions with third-party sponsors of such promotions (irrespective of whether such promotions are hosted by us), or otherwise in accordance with the rules applicable to such promotion. Please see the “Sweepstakes, Contests, and Other Promotions” section below for more information on participating in such activities.
- Assignment. We may transfer information that we collect from Services users to an Affiliated Entity or a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Liberty Hardware business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
HOW WE COLLECT AND USE OTHER INFORMATION
We may also collect other information that does not reveal your specific identity or directly relate to an individual through the Services (“other information”), such as domain, URL, browser, device and operating system information, information about visits to the Services pages, App usage data, physical location and information collected through cookies, pixel tags and other technologies, demographic information provided by you that does not reveal your specific identity, and information that has been aggregated in a manner such that it no longer reveals your specific identity.
We and our third-party service providers may collect other information in a variety of ways, including:
- Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Through your use of the Apps. When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to “information on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.
- Physical Location. We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
- From you. Information, such as your preferred means of communication is collected when you voluntarily provide it. Unless combined with personal information, this information does not personally identify you.
- By aggregating information. Aggregated personal information does not personally identify you or any other user of the Services (for example, we may aggregate personal information to calculate the percentage of our users who have a particular telephone area code).
We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat other information as personal information under applicable law, then we may use it for all the purposes for which we use and disclose personal information.
In some instances, we may combine other information with personal information (such as combining your name with your geographic location). If we do combine any other information with personal information, the combined information will be treated by us as personal information in accordance with this Policy.
SELLING OF PERSONAL INFORMATION
We do not sell your personal information or any other information we collect about you to any affiliated or unaffiliated third parties.
USER GENERATED CONTENT FUNCTIONS
Certain pages on the Services, including our Social Media Pages, enable users to create their own profile page or submit their own content (for example, message boards, forums, chat functionality and blogs, among other services). Any information you disclose in connection with such services may be publicly available and be read, collected, or otherwise used by anyone who visits the page on which you have chosen to comment, and you should exercise caution in deciding whether to disclose your information there. Liberty Hardware cannot prevent such publicly available information from being used by others in a manner that may violate this Policy, the law, or your personal privacy and safety, and is not responsible or liable for the results of any postings or the use or disclosure of any information that you disclose via such postings.
If you do not wish to receive marketing-related emails from us, or if you would prefer that we do not share personal information about you collected via the Services or otherwise with Affiliated Entities or other third parties for such Affiliates Entities’ or other third parties’ marketing purposes, you may opt-out of receiving such marketing-related emails and from such sharing by following the unsubscribe instructions contained in each such email. We will endeavor to comply with your request as soon as reasonably practicable. Please note that, if you opt-out as described above, we will not be able to remove personal information about you from the databases of Affiliated Entities or other third parties with which we have already shared your personal information as of the date on which we implement your opt-out request. If you wish to cease receiving marketing-related emails from such Affiliated Entities or other third parties, please contact such Affiliated Entities or other third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.
SWEEPSTAKES, CONTESTS, AND OTHER PROMOTIONS
We may operate sweepstakes, contests, raffles and similar promotions through the Services that may require online registration with us or with third-party sponsors of such promotions. You should carefully review the rules of each promotion in which you participate through the Services, as they may contain additional important information about Liberty Hardware’s or a sponsor’s use or disclosure of your personal information. To the extent that the terms and conditions of such rules concerning the treatment of personal information conflict with this Policy, the terms and conditions of such rules shall control.
In addition, we are not responsible for the information, collection, usage, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
SECURITY OF PERSONALLY IDENTIFIABLE INFORMATION
Liberty Hardware takes measures designed to protect personal information collected through the Services against unauthorized access, disclosure, alteration or destruction. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely 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 in accordance with the “Questions” section below.
For your own protection, we encourage you not to include sensitive personal information such as payment card information, in any emails you may send to us. Liberty Hardware will not request sensitive personal information in our emails to you.
Your personal information may be stored and processed in any country where we have facilities, where our Affiliated Entities are located, or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
If you have any questions under this Policy or how Liberty Hardware processes your personal information, you can reach Markus Armbruster, Vice President of Information Technology, who is responsible for overseeing our North American privacy and data security program, by emailing [email protected] or calling 1-833-724-0948.
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of personal information about California residents that we have collected or disclosed within the preceding 12 months:
- What We Collect. We collected the following categories of personal information:
- Identifiers, such as name, contact information, online identifiers (ex. IP address) and Social Security numbers and other government-issued ID numbers;
- Personal information, as defined in the California customer records law, such as name, address, telephone number, email, profile picture, social media account ID and profile pictures, date of birth, passwords and reminder questions/answers, payment card information, and information related to employment, education and experiences, preferences and interests;
- Characteristics of protected classifications under California or federal law, such as sex, marital status, age, race, disability, medical conditions, sexual orientation, gender identity and expression, citizenship, primary language, immigration status and military/veteran status;
- Commercial information, such as transaction information, purchase history, financial details and payment methods;
- Biometric information, such as fingerprints and voiceprints;
- Internet or network activity information, such as browsing history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements;
- Geolocation data, such as device location and IP location;
- Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities;
- Professional or employment-related information, such as work history, prior employer, information relating to references, CV, details of qualifications, skills and experience, human resources data and data necessary for benefits and related administration services;
- Education information subject to the federal Family Educational Rights and Privacy Act, such as student records; and
- Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
- From Whom We Collect. We collect this personal information from you and from other categories of sources, which include: our Affiliated Entities; public databases; joint marketing partners; social media platforms; from people whom you are otherwise connected with on social media platforms; and other third parties, when they share the information with us. We use and disclose this personal information to operate, manage, and maintain our business, to provide our products and services, for our vendor management purposes, to accomplish our business purposes and objectives, and for the purposes described above in this Policy.
- Why We Collect. We use your personal information to provide the services you request from Liberty Hardware such as responding to product information requests; registering products; fulfilling orders for parts, products or customer service; initiating refunds; administering contests or incentive programs; and facilitating on-line product visualization applications and preferred product catalogs. We also use personal information to send you news about our products and promotions, to conduct online surveys, contests, other similar promotions or incentive programs via email, telephone or postal mail, and to notify you of special events and advertising that you might be interested in. Please see the “Sweepstakes, Contests, and Other Promotions” section above for more information on participating in such activities. Further, we may also use personal information to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important to your use of the Services, you may not opt-out of receiving such communications. In addition, we may use the information to improve Liberty Hardware online and other services, such as through customer service and product support, to understand consumer preferences in developing product improvements and innovations. We may also use your personal information for internal business purposes, such as optimizing users’ Services, experiences and analyzing, managing, and expanding our businesses. If you apply for employment with Liberty Hardware, we may use the personal information you supply to process your job application.
- To Whom We Disclose. As described above in this Policy, we disclosed the following personal information to third parties, including our Affiliated Entities, service providers (including internet service providers and data analytics providers), business partners (including dealers, retailers and partners for co-branded pages), third-party sponsors of sweepstakes, contests and similar promotions, third parties to permit them to send you marketing communications, consistent with your choices, your social media account provider, third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), and public or government entities for our operational business purposes:
- We Do Not Sell. We have not “sold” personal information for purposes of the CCPA. For purposes of this Policy, “sold” or “sale” means the disclosure of personal information for monetary or other valuable consideration but does not include, for example, the transfer of personal information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
- Right to Request. If you are a California resident, you may have the right to request that we:
- Disclose to you the following information covering the 12 months preceding your request:
- The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
- The specific pieces of personal information we collected about you;
- The business or commercial purpose for collecting personal information about you and
- The categories of personal information about you that we otherwise shared or disclosed, and
- The categories of third parties with whom we shared or to whom we disclosed such personal information (if applicable).
- Delete personal information we collected from you.
We will respond to your request consistent with applicable law. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
- How to Make Requests.
Making Your Own Request. If you are a California resident, you may make a request for the disclosures described above or make a request to delete personal information we collected from you, by contacting us at:
1) (800) 635-2731 or
2) [email protected]
Making A Request Through Agent. If you are making a request on behalf of a California resident, you may make a request for the disclosures described above or make a request for the deletion of the personal information we collected from the California resident, by contacting us at:
1) (800) 635-2731 or
2) [email protected]
Additionally, agents must:
- Provide proof of agency (a writing signed by the California resident giving you permission to make the request on their behalf will suffice unless a power of attorney exists); and
- Verify your identity with us.
Residents using an authorized agent to make a request must confirm with the business, either verbally or in writing (email will suffice), that they provided the agent permission to make the request.
- How We Verify Your Identity. In order to process your request, you must provide us with the following personal information, which will be used solely for the purpose of verifying your identity:
- Phone; and
Upon receipt of this information, we will compare the personal information you provide in connection with your request to the consumer information we have in our systems and applications to determine whether or not we have any of your personal information. If additional information is necessary to verify your identity, we will send a Requesting Additional Information letter to you using the same method of communication you used to submit your request, unless you designate a different method of communication.