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Privacy Policy

Effective:  June 2019
Revised:    July 2020

Each of Bath Fitter Distributing Inc. and its affiliates (collectively and individually, “Bath Fitter” or “we”) values and respects the privacy of its customers and visitors of its website at https://www.bathfitter.com  (the “Website”). The purpose of this privacy policy (the “Privacy Policy”) is to provide you with information about how Bath Fitter collects, uses, and shares information it gathers from customers and Website visitors.  The Privacy Policy also describes the choices you can make about our use of your information.  Our collection efforts are designed to improve the purchasing experience of our customers and visitors, and to provide relevant information about our products, services, and promotions.


About This Privacy Policy
This Privacy Policy describes the privacy practices adopted by Bath Fitter, its subsidiaries, and affiliates (collectively and/or individually, “Bath Fitter”, “our”, or “we”). The Privacy Policy does not apply to Bath Fitter franchisees that are independently owned and operated, or personal data processed as a result of your visit to third-party websites accessible through our Website.
The Privacy Policy covers our interactions with our customers and visitors, including, but not limited to:
• Use of our Website, including the mobile interface;
• Entering into any agreement with Bath Fitter;
• Visits to our stores or attendance at one of our events;
• Any type of communication;
• Social media interactions on our Website and other third party websites, such as, but not limited to Facebook, YouTube, Pinterest, Google+, Instagram and Twitter;
• Viewing our online advertisements or emails; and
• Any interactions with or through our authorized service providers.


Contact information
We collect the names, phone number of your cell or home phone, email, postal address of our customers, who placed an order with us, entered into any agreement with us, completed our online form for a free in-home consultation, or contacted us for any other reason. Additionally, we may collect your purchase history, billing addresses, phone numbers, email addresses, and other digital contact information. We may also collect information that you provide to us about others.

Payment Information
When you make a purchase, we may collect your payment information, including information from your credit or debit card, check, PayPal account or gift card. If you apply for a Bath Fitter-administered loan or financing, we might collect any other information related to your application.

Demographic Information
We may collect information about reviews you submit and other data like your age and gender.

Location Information
If you use our mobile website (including the Website), mobile applications, or other smart device applications, we may collect location data obtained from your device. If you use our website, we may collect location data obtained from your IP address.

Social Media Information, and Information Provided Electronically
If you interact with us on social media, such as, but not limited to Facebook, YouTube, Pinterest, Google+, Instagram and Twitter, we may collect your user name, other identifiable personal information, and any of the information or content that you provide through our Website, device applications, or online forums.

Employment Information
If you apply for an employment opportunity, we may collect certain personal information that you provide to us (whether it be in a resume, cover letter or similar employment-related materials, or any applicable pre-screening questions).

Other Information
When necessary or advisable, we may collect your electronic signature. If you use our Website, we collect your IP (internet Protocol) address and other related information like the type of browser and operating system you are using. We might also track the pages you visit, look at which website you came from, or which website you visit when you leave us. We collect this information using the tracking tools described in the Tracking Tequniques section at the bottom of the Privacy Policy. To control those tools, please read the Privacy Preferences and Our Tracking Techniques sections.

To improve our products and services.
We may use your information to make Website, device application, or product and service improvements.

To look at Website and device application trends and customer interests.
We might use your information to customize your experience with us. We may collect information about your activities and interactions with various devices and link that information.  Through cross-device linking, we provide customers with a consistent experience across devices used.  We may also combine information we get from you with information about you we have received from third parties or publicly available sources to assess trends and interests.

For security and loss prevention purposes.
We may use your information to protect our company, our customers, or our Website. For example, we might use cameras in our stores to track store traffic and stock.

For our marketing.
In certain circumstances, we may send you communications about special promotions or offers via regular mail, email, or other electronic channels, including ads on social media platforms.  We may send you emails if you have registered on Website and indicated that you want to receive this information or if you gave us your information at one of our stores or events.  We may also notify you of new Website features or product and service offerings. To manage our communications with you, follow the instructions in the Privacy Preferences section below. We may use information collected across different online services and the various devices you use in order to deliver marketing communications (including online ads) based on your interests.  For example, if you view a product on our Website, you may see ads for that product on our or third-party websites and applications.

To communicate with you about your account, our programs, and any rebates.
We may contact you to inform you about changes to this Privacy Policy, the Terms of Use of our Website or device applications, or changes to any of our programs in which you might be enrolled. We may also tell you about issues with your orders or if there is a product or service rebate.

For employment purposes.
We may use the personal information you provide in connection with a job application or related inquiry for the purpose of processing and responding to your application or inquiry.

For social media.
When you engage with our content through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain social media account information (e.g., name, username, email address, gender) as determined by the settings of the social media services to deliver the content or as part of the operation of the Website, plug-in or application.  Social media platforms may collect information about your use of our services and may notify other users of the platform about your activities on our Website and device applications.  Social media services may also use cookies or other technologies to provide services or track your online activities over time and across multiple websites and device applications. Your interactions with social media features are governed by the respective privacy policies of the companies providing the features.

For other uses we may disclose to you.
We may also use your personal information, as permitted or required by applicable law allowed, including but not limited to, upon receiving your consent.

Information Sharing
We may share your information for our business purposes and as legally required or permitted, including, but not limited to:

With third parties who perform services on our behalf.
We share information with our service providers, such as Horizon Next, Google, Quanticmind, Bing, and Hotjar. We might also authorize our service providers to collect information on our behalf.  Some service providers may be located outside of the United States and/or Canada.  We might also share information with the vendors and manufacturers of our products and services to respond to your reviews and questions.

To offer financial products.
We use service providers to offer financial products, such as Wells Fargo, Snap, Greensky, Aqua Finance, Fortiva & Genesis Creditloans/financings. We may share personal information about you with these service providers in order to provide you with tailored information about products and services and special offers.  These service providers also have their own privacy statements that stipulate the manner in which they will collect, and disclose personal information.  We encourage you to review each service provider’s privacy statement at the time you submit your application for financial products.

With any successor to all or part of our business.
We may share, sell or disclose your information in case all or part of our business is sold, or in the course of preparation for or as part of that transaction.

In order to comply with applicable law.
We will disclose information to respond to a court order or subpoena.  We may also disclose information if a government agency or investigatory body files a request.

With our business partners.
We might share information with one of our franchisees or a business partner who is running a joint promotion with us or who provides a product or service in partnership with us.  These franchisees and business partners should also have their own privacy statements that set out the manner in which they will collect, and disclose personal information.  We encourage you to review each such franchisee or business partner’s privacy statement before signing on with them

To protect us, or a third party.
We will disclose information if we suspect fraud, or in any other case to protect us, or any third party.  We will also share information as part of an investigation.  We may also disclose personal information to assist us in collecting a debt owed by you.

By your request.
For example, if you ask us to provide your information to a third-party to facilitate the resolution of a dispute.

Your Privacy Preferences
You can register or change your preferences to receive or not receive marketing communications from us by emailing us.  Please allow sufficient time for your preferences to be processed.  Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on an order or service request, responding to customer service inquiries, asking you to review a product or service you have ordered, or notifying you of product or service rebates. If, in the future, you do indeed want to receive marketing communications from us we will remove your information from our opt-out database.
For more information about how we may collect information to provide you with interest-based ads or learn about our users’ interests and how you may register your preferences regarding that collection, please read the Tracking Techniques section below.

Our Sites and Children
Our Website and device applications are not created for children.  No one under age of 16 may provide any information to us or on Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].  
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights below for more information.

Privacy Policy According to the GDPR
Welcome to Bath Fitter Limited’s (“Bath Fitter”) privacy policy. Bath Fitter respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

This privacy policy aims to give you information on how Bath Fitter collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or marketing emails, or make any enquiry for information from us, or contact us to set up an appointment. 
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Bath Fitter Limited, incorporated in Ireland with registered number 658308 and located at Units 25 & 41 Eastlink Business Park, Ballysimon, Limerick, Ireland, is the controller and is responsible for your personal data (collectively referred to as ”Bath Fitter”, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email address: [email protected]
Postal address: 225 rue Roy, St Eustache, Quebec, J7R 5R5, Canada
Telephone +1 450 472 0027 x6420

You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us directly in the first instance.

We keep our privacy policy under regular review. This version was last updated on 29 June 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes name, username or similar identifier, title.
Contact Data includes location address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your interests, preferences, feedback and any survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• contact us with an enquiry;
• request marketing to be sent to you or subscribe to any newsletters or
• other information we make available from time to time;
• enter a promotion or survey; or
• give us feedback.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [HYPERLINK] for further details.

Third parties. We will receive Technical Data relating to you from Google Analytics. 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Click here [HYPERLINK TO GLOSSARY, “LAWFUL BASIS”] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you no longer wish to receive marketing information from us, please contact us at [email protected] at any time to let us know and we will cease all marketing communications to you.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing, or where you give us consent to market to you.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at [email protected]
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy below.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table Purposes For Which We Will Use Your Personal Data above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within other entities in the Bath Fitter group, including Bath Fitter Distributing Inc. based in Montreal, Canada. This will involve transferring your data outside the European Economic Area (EEA).  Other entities in the Bath Fitter group including Bath Fitter Distributing Inc. may share your data with other third parties who are providing business support services to them.   Any transfers of such data will take place pursuant to written agreements which contain provisions to safeguard your data.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for certain regulatory purposes.
In some circumstances you can ask us to delete your data: See Your Legal Rights in section 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary for more information about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact our data privacy manager.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our data privacy manager.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request (or in response to an enquiry from you) before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Other companies in the Bath Fitter group including Bath Fitter Distributing Inc. and who are based in Canada and other countries acting as controllers and processors and who provide IT, system administration, support and maintenance, management, hosting of data, financial and business support services

Service providers acting as processors based in the EEA and outside of the EEA who provide business support services, IT, HR, marketing, customer experience and system administration services.
Service providers acting as processors based in the EEA and outside of the EEA who provide surveying, measurements, photographic, design, fabrication, repair and installation services.
Professional advisers acting as processors and controllers including lawyers, marketing agencies, bankers, auditors and insurers based in the EEA and outside of the EEA who provide consultancy, banking, legal, insurance and accounting services.
The Revenue Commissioners, regulators and other authorities acting as controllers based in Ireland who require reporting of processing activities in certain circumstances.
 Contractors for after sale/installation services
You have the right to:
     Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Your California Privacy Rights
Privacy Notice for California Residents According to the CCPA

This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section of Privacy Policy.

Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:
·         Publicly available information from government records.
·         Deidentified or aggregated consumer information.
·         Information excluded from the CCPA’s scope, like:
·         health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
·         Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Use of Personal Information
Purposes of use or disclosure of your Personal Information are set forth in Section “How We Use Information” of this Privacy Policy.

Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose, which may include sharing information about our customers or our visitors with Facebook. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Bath Fitter has disclosed Personal Information for a business purpose. In particular, the following categories of Personal Information regarding Bath Fitter’s customers have been disclosed for a business purpose: category A (Identifiers), category B (Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))), category F (Internet or other similar network activity), and category G (Geolocation data).
With respect to employees, the following categories of Personal Information have been disclosed: category A (Identifiers), category C (Protected Classification Characteristics under California of Federal law), category G (Geolocation Data), category H (Sensory Data), and category I (Professional or Employment-related Data).

Sales of Personal Information
In the preceding twelve (12) months, Bath Fitter has not sold any Personal Information.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
·         The categories of Personal Information we collected about you;
·         The categories of sources for Personal Information we collected about you;
·         Our business or commercial purpose for collecting or selling that Personal Information;
·         The categories of third parties with whom we share that Personal Information;
·         The specific pieces of Personal Information we collected about you (also called a “data portability request”);
·         If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
·         sales, identifying the Personal Information categories that each category of recipient purchased; and
·         disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
·         Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
·         Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
·         Debug products to identify and repair errors that impair existing intended functionality;
·         Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
·         Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
·         Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
·         Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
·         Comply with a legal obligation;
·         Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at [email protected], or mail us at 225 Roy Street, Saint-Eustache, QC, J7R 5R5, Canada.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:
·         Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative;
·         Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
·         Deny you goods or services.
·         Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
·         Provide you a different level or quality of goods or services.
·         Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

While we use industry standard means to protect our Website and your information, the Internet is not 100% secure.  The measures we use are appropriate for the type of information we collect.  We cannot guarantee use of our Website or mobile applications are 100% secure. We encourage you to use caution when using the Internet.

Our Website contains links to third-party websites.  If you click on one of those links, you will be taken to websites we do not control. This Privacy Policy does not apply to the information collected or processed by those websites. You should carefully read the privacy policies of other websites.  We are not responsible for third-party websites.

Our Tracking Techniques
Tracking Tools We Use
We collect personal and other information about users over time and across different websites, including the Website and devices when you use this Website or service. We also have third parties that collect personal information this way, or our vendors, use several common online tracking tools to collect this information. These may include browser and flash cookies. We may also use web beacons and similar technologies.  We or third parties may also collect or receive information from our device applications and others’ device applications and use that information to provide measurement services and targeted ads.  We (and our third party service providers) also use these tools:
·         To track new visitors to our Website
·         To recognize returning customers
·         To learn what site referred you to our Website or device application
·         To personalize your experience on our Website, device application and on third-party social networking websites, plug-ins and applications
·         To collect and store geographic data determined by the IP address of your computer
·         To optimize and tailor our Website and device applications
·         To make product recommendations and provide you with advertising content we believe may be of interest to you.  As part of this customization, we may observe your behaviors on our device applications, our Website or on other websites.  We may also get information about your browsing history from our trusted business partners and vendors
·         So we can better understand our audience, our customers, our Website visitors and device application users, and their respective interests, which includes learning about your online activities across devices

Controlling Our Tracking Tools
Your browser may give you the ability to control cookies, and browser add-ons like Ghostery allow you to decide which cookies to activate/deactivate.  How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies.  To control flash cookies, click: http://www.macromedia.com/support/documentation/en/flashplayer/
Why? Because flash cookies cannot be controlled through your browser settings. Your device may not give you the ability to control cookies. If you configure your computer to block cookies, you will limit the functionality we can provide when you visit our Website.  If you configure to block or delete cookies, not all of the tracking that we have described in this Privacy Policy will stop.
Our “Do Not Track” policy: Some browsers have a “Do Not Track” feature that lets you inform Website that you do not want to have your online activities tracked.  These browser features are not uniform, so we are not currently set up to respond to those signals.

Controlling Online Interest-Based Ads
We sometimes work with online advertising vendors to provide you with relevant and useful ads.  This may include ads served on our Website or device applications.  This may also include ads served on other websites.  These ads may be based on information collected by us or third parties.  For example, information a third party collects when you register on a website: e.g. your zip code.  This might be used to target an ad for people in your area.  These ads may also be based on your activities on our Website or on third-party websites.
 To learn more about interest-based ads and to opt out of certain types of interest-based advertising and certain other uses of information collected over time and across different online services and devices.  To opt out of certain interest-based advertising associated with your use of device applications, you may be able to adjust your device settings via the “Limit Ad Tracking” setting for iOS devices or the Android “Opt out of Ads Personalization” setting for Android devices. Please see the support materials for your operating systems or devices for more information.
 Some of the social media platforms we work with may serve you with interest-based advertising on their platforms.  In addition to or instead of the opt-out mechanism linked above, you may be able to opt out of their interest-based advertising by changing your advertising preferences in the platforms after you log in.

Free In-Home Consultation
The Free In-Home Consultation is an optional form to fill out if you are interested in a Bath Fitter product.  You do not have to fill out the form to browse our Website online.  When filling out the form, you are asked for personal information such as your name, address, phone number and email address that you select.  This information may be used to help our sales representatives contact you to answer any questions or provide you with a free in-home consultation appointment.

Contact Us
If you have additional questions you may call us at 1-800-764-5539 or reach us by email at [email protected].  You can write to us at 225 Roy Street, Saint-Eustache, QC, J7R 5R5, Canada.

Changes to this Privacy Policy
Effective Date: 6/14/2019
Last Revision Date: 7/2/2020
From time to time we may change our Privacy Policy. We will notify you of any material changes to our Privacy Policy by posting an updated copy on our Website.  Please check our Website periodically for updates.