CULLIGAN (UK) LIMITED – PRIVACY POLICY

March 2024

This notice sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data (e.g. name or address) changes during your relationship with Us so that We can update our records.

This privacy notice explains:

• Who We are;
• Your rights;
• What personal information We collect;
• How We Use your personal information;
• Who We share your information with and why;
• How We keep your information secure;
• How long we keep your information; and
• How to contact Us.

In this document, “We”, “Us” and “Our” refers to Culligan (UK) Limited, Company number 02418453, Fourth Floor Abbots House, Abbey Street, Reading, Berkshire, United Kingdom, RG1 3BD.

1. Who we are

For the purposes of data protection laws, We are the Data Controller and a proud member of the Culligan International Group (“Culligan”). Culligan is the global leader in providing cleaner, softer water through innovative, sustainable solutions and unparalleled service across all sectors.

With more than 13,000 team members and 1,000 dealers in 90 countries, Culligan’s 35+ brands serve more than 50 million customers every year and share a mission of bringing better water to consumers anywhere they need it – in the home, at work or on the go.

This Privacy Notice covers all entities within the Culligan Group. However, these companies may also host their own Privacy Notice which could augment this document. If you are resident in the EU (or a country that has adopted a local law to implement or adopt the GDPR) (“EU Residents”), this will include the European General Data Protection Regulation (“GDPR”) or the applicable local law implementing or adopting the GDPR.

We have also put in place an intercompany agreement which contains the Standard Contractual Clauses approved by the European Commission to ensure that all transfers of Personal Data to any entity of Culligan are protected to the same level as required under European data protection legislation.

2. Your legal rights

You have the right to ask us:

• whether we are processing your personal information and the purposes (the right to be informed) – this is delivered through ‘fair processing information’ such as this Privacy Notice;
• for a copy of the personal information that we hold about you (the right of access);
• to update or correct your personal information (the right to rectification);
• to delete your information (the right to erasure); and
• to restrict processing of your personal information where appropriate (the right to restrict processing).

In certain circumstances you also have the right to:

• object to the processing of your personal information (the right to object);
• object to automated decision making and profiling (the right not to be subject to automated decision- making including profiling); and
• request that information about you is provided to a third party in a commonly used, machine readable form (the right to data portability).

Exercising your rights

For information about your individual rights, including how to correct, restrict, delete, make changes to your personal information or if you wish to request a copy of the personal information we hold about you, please contact us here.

Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If you are not satisfied with our response or for more information about your data protection rights you can visit the website of your local Data Protection Authority.

• In the UK, please see the Information Commissioner’s Office (ICO) website.
• In the EU, you can find your local DPA here.
• In Switzerland, please see the Federal Data Protection and Information Commissioner (FDPIC).

3. What personal information we collect

“Personal data” means any information about an individual from which that person can be identified directly or indirectly. We will collect personal data relating to you that you provide when you apply for employment. This information includes personal data, such as your full name, email address and telephone number, job title, department, preferences and our communications with you.

Information you provide

 We will collect personal data relating to you that you provide when you:

• fill in a contact form on our website;
• contact us about products and/or services;
• subscribe to any of our services;
• register for a free trial;
• login to our portal and/or any of our apps;
• respond to a survey;
• request to download guides or other resources on our website;
• attend product events;
• engage with Us via our social media channels;
• opt-in (consented) to receive marketing communications from Us; and/or
• apply for employment.

This information includes personal data, such as your full name, email address and telephone number, job title, department, preferences and our communications with you.

Information We collect about you

 The type of personal information we collect will depend on the purpose for which it is collected and may include:

• Information about you to help identify you and manage your relationship with Culligan (e.g., Name, Address, Email Address(es), Postcode, Telephone Number(s), Title, Gender);
• Information about your account with us (e.g. Account number, Customer ID or Number Past engagements with Us, Personal Preferences, order history etc.);
• Copies of documentation (e.g. statements, letters, invoices, correspondence);
• Economic & financial information (e.g. payment card numbers, bank details, payment history, we also collect a certain amount of data on behalf of financial institutions concerning the purchase of devices financed by a loan (e.g. payslips, proof of address, etc.));
• Audio & Visual information when we are recording interactions with you, or when you visit one of our premises (e.g. call recordings or Closed Circuit Television “CCTV”);
• Marketing / Communications Data (e.g. information relating to Marketing and external communications such as marketing campaigns, opt in information and preferences); Where we have used consent as our lawful basis to contact you, this may be withdrawn at any time;
• Lifestyle information (e.g. water consumption volume, mineral/vitamin supplements, Information necessary to choose the right equipment for your home, such as the number of people living in the home in question, your consumption of tap water, your electricity consumption);
• Information about your website visit, Internet Protocol (IP) address Used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods Used to browse away from the page and any phone number used to call our customer service number;
• Employment and educational information (e.g. employer details, relevant professional qualifications, etc).

 We may also collect information about you from other sources such as:

• other companies within the Culligan Group;
• external third parties (e.g. credit reference agencies to verify your identity and to check financial soundness, event coordinators where our attendance at a stand is present); and
• from Cookies. (Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners).

4. How we use your personal information

We will only Use your personal data when the law allows Us to and for the purposes set out in this Notice. These are:

• When you give your consent
• When necessary for the performance of a contract We have entered into or are entering into with you
• When necessary to comply with a legal or regulatory obligation
• For our legitimate interests or those of a third party, provided that your interests and fundamental rights and freedoms do not override those interests.

We may Use your personal data in the provision and administration of the services that you have requested and/or to respond to your queries. Where you don’t provide Us with certain information We may be unable to process your order.

We may also Use your personal data to meet our legal obligations, to deal with any complaints and for the enforcement of our terms and conditions.

We may Use your personal data for our legitimate business interests which include security purposes, improvements to our Website, improvements to our solutions and services and for general marketing purposes and internal monitoring and reporting. We will not do so though where our interests are outweighed by your interests, rights and freedoms.

We process your information for the following purposes

We have set out below a description of the ways We plan to Use your personal data.

To perform our contract with you and to support and maintain that relationship. This includes the following:

• to register you as a potential or new customer;
• to process and deliver your order including managing payments, fees and charges and collecting and recovering any monies owed to Us;
• recording specific needs or adjustments you have or may require from time to time such as text to speech, large print or medical reasons which allow us to better assist with your understanding of our products and services;
• as part of our recruitment activities.

To comply with legal and regulatory requirements. These requirements include the following:

• confirming your identity for regulatory purposes;
• detecting and preventing fraud;
• to fulfil our data protection obligations.

For specific business purposes to enable us to provide you with appropriate products and services and a secure experience. Our business purposes include the following:

• to manage our relationship with you which will include notifying you about changes to our terms or privacy Notice and/or asking you to leave a review or take a survey;
• to send you newsletters, to keep you updated on new products or services or to recommend other goods or services that may be of interest to you, to let you know about special offers and to invite you to our events;
• to administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• to deliver relevant Website content and advertisements to you and measure or understand the effectiveness of that advertising;
• to Use data analytics to improve and develop our Website, products/services, marketing, customer relationships and experiences.
• monitoring or recording communications (such as telephone and video calls) with you to resolve any queries or issues and also for training and quality purposes and;

We may utilise AI technologies and Internet of Things “IoT” data, including machine learning, to perform some activities. Where this is the case, the output is subject to human oversight and review, and we will not include your personal data in any data analytics with a third party model without making you aware. Where we are using publicly available models for general business purposes, we will give you the option of being anonymised or omitted from the data provided. We will always endeavour to utilise AI technologies in line with legislation, regulatory guidance and governmental policy.

Change of purpose

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. We may also process your personal data as part of an acquisition or sale. Should this happen, you’ll be notified about any change to processing or data controller arising as a result of this activity.

You have the right to object to us processing your personal information for some of the business purposes listed above but, if you do so, this may impact on our ability to provide some or all of our services to you. 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.

5. How we keep your information secure

We’re committed to ensuring the confidentiality of the personal information that we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure and prevented from unauthorised or accidental access, processing, copying, modification, erasure, loss or use.

If we work with third parties in countries outside the United Kingdom- or the European Union, we ensure these are countries that the UK Government and the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards and agrees to treat your information with the same level of protection as we would.

We also utilise UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside of the United Kingdom or European Economic Area.

In limited circumstances, data may be accessed by employees outside of our usual operating locations.  In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.

6. Who we share your information with and why

We will not sell your personal data and generally do not give your personal data to third parties but there are some exceptions. We may share your personal data in the following ways (as appropriate):

• Companies within the Culligan Group
  • for administrative, analytical and statistical purposes;
  • for testing the information systems operated by our companies;
  • for producing a consolidated view of our relationship with you in order to enhance the services we can offer you;
  • for sending marketing communications to you which you have opted (consented) into receiving, or which we think may interest you based on the services you receive from us or other companies in our group;
  • for providing service messages which are relevant to our relationship with you;
  • for handling complaints and fulfilling data subjects’ rights (such as the Right of Access).

• Companies appointed by Culligan (these third parties may be based in countries outside the UK or EU)
  • with third parties or service providers who provide additional data about you in order to enhance our ability to design and develop new products and services that can be marketed and sold which meet the needs of our identified consumer groups and are targeted accordingly;
  • with debt collection agencies for tracing and recovery of debts;
  • with payment service providers to allow payments to be completed;
  • with our accountants to produce tax statements and in support of statutory reporting;
  • with our appointed legal or regulatory advisers or auditors;
  • with information technology and information security providers;
  • with third parties or service providers to conduct market research on our behalf, to help us improve and develop the products and services we provide to you and our other customers;
  • with a prospective buyer (or its advisors), for due diligence purposes, if we are considering a sale of any of all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control or liquidation of Culligan or part of its business (or in anticipation of such an event), we may share your personal data as part of that transaction where required in order to fulfil our obligations in this Notice.

• Organisations and parties appointed by you or authorised by you
• Statutory authorities
  • for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, We may share any personal data that We collect with law enforcement, other public or private sector agencies, governmental or representative bodies in accordance with the relevant legislation in order to comply with any legal obligation or as otherwise permitted by law. This will include public authorities, insurance companies, finance companies and/or other agencies.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Where processing is based on your consent, We shall only process your personal data until such time as you withdraw your consent.

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 requirements.

We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Notice.

3. How to contact us

If you have questions about this notice, or need further information about our privacy practices, or wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.