SunTouch is a subsidiary of Watts Water Technologies, Inc. (Watts)
Version 1.1, Modified 16 July 2020
11. Data Security
Watts Water Technologies, Inc. and its affiliates, subsidiaries, divisions and companies (collectively "Watts", "we", “our” or "us") respect your privacy and are committed to protecting it.
- Visit (whether as a guest or a registered user) our websites, including www.watts.com (and any successor site thereto) and any other websites that are owned or maintained by or on behalf of Watts (the “Websites”);
- Use our mobile and desktop applications (the “Apps”);
- Use any software, software-as-a-service, content, information, functionality, and services offered on, through, or in connection with our Websites and Apps (together with the Apps and Websites, the "Connected Offerings");
- Purchase and use the connected functionality of products that access any of the Connected Offerings (the “Connected Devices”).
3. Persons Under the Age of 18
We respect the privacy of children. Our Services are not designed to attract an audience younger than eighteen (18), and we do not knowingly collect Personal Information from persons under eighteen (18). If you are under the age of eighteen (18), you are not permitted to use our Services and should not send any information about yourself to us through the Services, or otherwise. Please contact us using the contact details below if you believe we may have collected information from your child under the age of eighteen (18), and we will delete it.
4. Information We Collect About You and How We Collect It
a. We may collect several types of information from and about users of our Services, including information:
i. About you, including how to contact you, such as name, postal address, e-mail address, and telephone number.
ii. About your internet connection, the desktop computer, tablet computer, cell phone, or other electronics devices (“Electronic Devices”) you use to access our Connected Offerings, and usage details.
iii. That is location-based. For example, when you use one of our Apps the Electronic Device you use with our App may provide location information to the App.
iv. Collected by Connected Devices, such as location-based information, environmental information such as temperature of the location where the Connected Device is installed or used, and/or product usage information (e.g., water usage, component part status, leak detections).
v. That you provide to us through or in connection with the Services (the “Data”) including (i) information about you and (ii) information about products, such as installation information, serial numbers, registration, warranties, servicing and testing information, images and locations of products, including but not limited to Watts products that include or operate with Connected Devices, and other Watts or third party products (the “Product Data”). For clarity, Product Data does not include information about you.
b. We collect this information:
i. Directly from you when you provide it to us.
ii. Directly from you when you register your products for use with our Services.
iii. Automatically as you navigate through the Connected Offerings. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
iv.Automatically from Connected Devices when you connect to our Connected Offerings via Wi-Fi or our third party cellular service and also any Connected Device that you register with Watts.
v. When you use our Connected Offerings to scan labels, such as QR codes, take images, determine locations, or record other information needed by the Connected Offerings.
vi. From third parties, for example, our business partners, such as our sales representatives and marketing services.
vii. From social media platforms, such as Facebook, LinkedIn, Instagram and Twitter.
5. Information You Provide to Us.
The information we collect through our Services may include:
i. Information that you provide to use our Services, such as while creating an Account and/or registering for the Apps.
ii. Records and copies of your correspondence (including e-mail addresses), if you contact us.
iii. Your responses to surveys that we might ask you to complete for research purposes.
iv. Details of transactions you carry out through our Connected Offerings and the fulfillment of your orders. You may be required to provide financial information before placing an order through our Connected Offerings.
v. Your search queries on the Connected Offerings.
vi. Information related to your use of our Services, such as water usage, leak detections, filter status, type of filter and backflow testing results.
vii. Data you have entered into our Connected Offerings to perform your work, such as Product Data.
viii. Login credentials for your accounts, including a user name or email address and a password.
6. Usage Details, IP Addresses and Cookies and Other Technologies.
a. As you navigate through and interact with our Connected Offerings, we may automatically collect certain information about your products, Electronic Devices, usage, browsing actions and patterns, including:
i. Details of your use of our Connected Offerings, or use of our products, including traffic data, location data, logs and other communication data and the resources that you access and use on the Connected Offerings.
ii. Information about your Electronic Devices and internet connection, including your IP address, operating system and browser type.
iii. The information we collect automatically is statistical. It helps us to improve Services and to deliver a better and more personalized service by enabling us to:
iv. Estimate our audience size and usage patterns.
v. Store information about your preferences, allowing us to customize our Connected Offerings according to your individual interests.
vi. Speed up your searches.
vii. Recognize you when you return to our Connected Offerings.
viii. Track where and when products are installed and the service and testing history of the products.
ix. Determine how customers use our Services.
x. Learn how to improve our Services, based on customer use and preferences.
xi. Provide product recommendations for other products that we offer. For example, we may use water quality testing results submitted through our Services to recommend water filter products.
b. The technologies we use for this automatic data collection may include:
ii. Flash Cookies. We may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. Flash cookies can be disabled through the Adobe Flash Player Settings manager.
iii. Web Beacons. Pages of our Connected Offerings may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Watts, for example, to count users who have visited those pages and for other related statistics relating to access to the Connected Offerings (for example, recording the popularity of certain Connected Offerings content and verifying system and server integrity).
iv. Google Analytics. To help analyze how visitors use our Services, we may use Google Analytics, which places cookies on your Electronic Device to collect standard Internet log information and visitor behavior information in an anonymous form. The anonymous information generated by Google Analytics cookies about your use of our Services is transmitted to Google. This information is processed to compile statistical reports on activity for our Connected Offerings only. We use these reports to evaluate aggregate visitor usage so that we can optimize the content, and its marketing, to better meet your needs. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html
v. Targeted Advertising. While on our Websites, third parties with whom we work may place cookies on your browsers for purposes of tracking consumer behavior, and sending you targeted online and offline advertising including direct mail related to our products.
vi. We do not collect Information automatically, but we may tie this information to other information about you that we collect from other sources or you provide to us.
7. How We Use Your Information
a. We use information about you:
i. To present our Services and its contents to you.
ii. To conduct research and analysis to help us analyze your purchasing preferences, identify the products and services that best meet your requirements and measure the effectiveness of the advertising we serve you.
iii. To provide you with information, products or services that you request from us or subscribe to.
iv. To provide training and information on using, servicing, selling, and displaying our products and services, including the Services.
v. To market and advertise our products and services, including the Services.
vi. To fulfill any other purpose for which you provide it.
vii. To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collection.
viii. To notify you about changes to our Services.
ix. To allow you to participate in interactive features, if any, on our Connected Offerings.
x. To facilitate the functioning of the Services.
xi. In any other way we may describe when you provide the information.
xii. For any other purpose with your consent.
b. Such information will be maintained by Watts for a period that is reasonably necessary for the purposes collected.
8. Disclosure of Your Information
a. We may aggregate and/or anonymize your personal information so that it can no longer be used to identify you. Aggregated or anonymized information is not considered personal information. We may collect, use and share aggregated or anonymized information for any purpose in accordance with applicable law.
b. We may disclose information that we collect, or you provide, as follows:
i. To our subsidiaries, affiliates and any successors, as permitted and in accordance with any applicable laws. Since we are a U.S. based company, it is probable that those subsidiaries, affiliates and any successors will be in the U.S.
ii. With our independent sales representatives for purposes of providing you with additional information on our products and services. Our sales representatives are separate legal entities from us. In addition, information that you share with our sales representatives may be provided back to us. The independent sales representatives will most likely be in your country but may be in an adjacent country. For example, if you live in Canada, our closest independent sales representative may be in the U.S.
iii. To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep your information confidential and use it only for the purposes for which we disclose it to them. This may include our third party cellular service provider that provides free cellular connectivity for your use of the Services and our third party hosting services providers that host our Connected Offerings, process credit card transactions and provide such functions as data management, analytics and reporting on behavioral data, marketing campaigns, direct-mail services, and technology services that utilize third party customer data and match it against your personal information. It is likely that the contractors, service providers and other third parties we use will be in the U.S.
iv. To fulfill the purpose for which you provide it. For example, if you give us an e-mail address to use the "e-mail a friend" feature of our Connected Offerings, we will transmit the contents of that e-mail and your e-mail address to the recipients.
v. With other users who scan a label on a product to retrieve Product Data related to that product which you may have provided to us through our Connected Offerings. This section does not apply to information provided through our Syncta® Services.
vi. To comply with any court order, law or legal process, including responding to any government or regulatory request.
viii. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Watts, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
ix. With third parties in connection with the sale of our business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings).
x. Otherwise as permitted by applicable law.
xi. For any other reasonable purpose disclosed by us when you provide the information.
xii. With your consent.
9. Choices About How We Use and Disclose Your Information
a. We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:
ii. Promotional Offers from Watts. If you wish to have your e-mail address/contact information used by Watts to promote our products or services, you can “opt-in” by checking the relevant box located on the form on which we collect your data (the contact form/order form/registration form), if any, on our Services. You may “opt-out” at any other time by sending us an e-mail stating your request to firstname.lastname@example.org. In addition, whenever we contact you via email, we will provide instructions on how to unsubscribe, or opt-out, so that you will not receive any future emails.
iii. Registration of Products. If you do not wish to have information collected via a product you purchase from us, you can choose not to register your product with any Connected Offering or contact us to de-register any Connected Offering you previously registered. Be advised, however, that failing to register or de-registering a product will deactivate certain functions of such product.
10. Anti-Spam Law and Email Opt-Outs
When you submit inquiries, or register the products on any of Watts' Connected Offerings, or otherwise request information, you may be asked to provide prior express consent for Watts to send you “commercial electronic messages” (CEMs), which includes text messages, e-mail messages, etc. If you do not provide such consent, we may not be able to respond to your inquiry. You can opt-out of receiving CEMs by unsubscribing using instructions contained in the CEMs or by sending an e-mail stating your request to opt-out to email@example.com.
11. Data Security
Data security is important to Watts and we care about the security of the information that you submit to us.
Your browser session will enter a secure encrypted protocol once you enter our Websites. You can confirm that SSL is active by checking for either a closed lock or an unbroken key in your browser (location of the lock or key varies between browsers). Additionally, the URL line of your browser will change from "http" to "https" when the SSL technology is operating.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential.
Unfortunately, the transmission of information and storage of data via the Internet is not completely secure. Although we endeavor to protect your information, we cannot guarantee the security of your information transmitted to our Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Services.
12. International Visitors
If you are accessing our Services from the European Union or other regions with laws governing data collection and use that may differ from U.S. and Canadian laws, then please note that you are transferring your personal data to the United States and/or Canada and by providing your personal data you consent to that transfer.
13. Additional terms for California Consumers and Canadian Residents
i. What is Personal Information? As used in this section “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. “Personal information” does not include publicly available information lawfully made available from federal, state, or local government records. “Personal information” also does not include consumer information that is deidentified or aggregate consumer information.
1. Watts employees, job applicants, directors, officers, or independent contractors (collectively, “HR Individuals”), or the emergency contacts of HR Individuals or the dependents or spouses who receive Watts benefits by virtue of their relationship to an HR Individual in their capacities as HR Individuals or emergency contacts, dependents, or spouses; or
2. Employees or other agents of a business engaged in a transaction with Watts in their capacities as employees or agents of that business.
b. Watts’ Collection, Use, Sale and Disclosure of Personal Information
i. Unless we inform you otherwise, this section serves as our “notice at collection” for California Consumers and Canadian residents by informing you of your Personal Information to be collected in the future and the purposes for its use.
ii. In the table below, we explain:
1. Categories of Personal Information we have collected within the last twelve (12) months and that we may collect, both online and offline, including through the use of our Services;
2. How we collect Personal Information and what activity or scenario you may be involved in when we collect your Personal Information; and
3. How we use Personal Information, and the purposes for collecting and using it.
The categories of Personal Information that we collect
How we collect Personal Information
How we use Personal Information
Commercial information, including
Product and service usage information, including
Internet or other electronic network activity information, including,
Geolocation Data, including:
Sensory information, including
Professional or employment-related information, including
Inferences drawn from Personal Information including:
iii. Sale and Disclosure of Information:
1. Watts does not and will not sell Personal Information.
2. In the preceding twelve (12) months, Watts disclosed the following categories of Personal Information about California Consumers and Canadian residents to the following categories of third parties for a business or commercial purpose:
Category of Personal Information
Categories of Third Parties
Internet or Other Electronic Network Activity Information
Professional or Employment-Related Information
c. To the extent conferred by the CCPA or Canadian privacy laws, California Consumers and Canadian residents will have the following rights, subject to verification.
i. Right to Access: You may request the information we have collected from and about you over the past 12 months including: (1) the categories of Personal Information we have collected, (2) the categories of sources from which the Personal Information is collected, (3) the business or commercial purpose for collecting your Personal Information, (4) the categories of third parties with whom we have shared your Personal Information, (5) the specific pieces of Personal Information we have collected about you, and (6) the categories of Personal Information we disclosed for a business purpose.
ii. Right to Correct: You may request that we make corrections to the Personal Information we may have about you.
iii. Right to Opt-Out: You may opt-out of receiving “commercial electronic messages” (CEMs), which includes text messages, e-mail messages, etc. This will remove you from all marketing lists but allow us to continue presenting our Services and its contents to you as long as you continue to use those Services.
iv. Right to Delete: You may request that we delete any Personal Information we have about you. This will include deletion of all account information you may have provided us and could affect the Services we are able to offer you.
d. How to Exercise Your Rights
Watts will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers and Canadian Residents can exercise their rights in the following ways:
i. Complete the online request form available at www.watts.com/support/ccpa, or
ii. Contact us by email, telephone or mail using the contact information listed below.
e. Requests by Authorized Agents
You may designate an authorized agent to exercise your rights. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California or Canadian law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described below for verifying your identity.
f. How We Will Verify Your Requests
i. The processes that we follow to verify that the person making a request is the person about whom we have collected Personal Information are described below. The relevant process depends on how and why the request is submitted.
1. Requests Through Your Password-Protected Account: If you created a password-protected account with us before the date of your request, we will rely on the fact that your request has been submitted through your account as verification of your identity. We will require that you re-authenticate yourself before we carry out your request.
You are responsible for protecting the security of your log-in credentials for your account. Please do not share your log-in credentials with anyone. If we suspect fraudulent or malicious activity on or from your account, we will not respond to a request until we have been able to confirm, through further verification procedures, that you made the request.
2. Requests Other Than Through A Password-Protected Account: If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:
3. Requests To Know Categories Of Personal Information: We will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or information about products or services that you have purchased from us.
4. Requests To Know Specific Pieces Of Personal Information: We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity.
5. Requests To Delete Personal Information: Our process for verifying your identity will depend on the sensitivity (as determined by Watts) of the Personal Information that you ask us to delete. For less sensitive Personal Information, we will require a match of two data points. For more sensitive Personal Information, we will require a match of three data points.
ii. We have implemented the following additional procedures when verifying the identity of requestors:
1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process. We will not use that information for any purpose other than verification.
2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.
g. Watts’ Non-Discrimination Policy
California Consumers and Canadian residents have the right not to be subject to discriminatory treatment by Watts for exercising their privacy rights under the CCPA, and Watts will not discriminate on that basis.
h. Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes
California Consumers and Canadian Residents can request information from us whether we have disclosed Personal Information to any third parties for the third parties' direct marketing purposes. We will not sell your Personal Information to, or share it with, third-party companies for their direct marketing purposes without your consent. California Consumers and Canadian Residents desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.
i. Your ‘Do Not Track’ Browser Setting
Watts does not track you over time and across the Web to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. But we may use third party services, such as Google Ad Words, which do track you over time and across the Web to provide targeted advertising. Your browser can be set to DNT to stop such tracking.
14. Contact Information
By Email: firstname.lastname@example.org
By Mail: Watts Water Technologies, Inc.
815 Chestnut St.
North Andover, MA 01845-6098
By Phone: 877-689-6066 (toll free)
You can also contact us, as indicated above, if you have any concerns about our handling of your information, if you wish to access and/or correct your information, and/or to withdraw your consent to our continued collection, use or disclosure of your information (subject to reasonable notice and any other applicable legal limitations).
Thank you for using our Services.