Effective Date: June 1, 2020
WIN Health Labs, LLC. (“WIN Health”), a subsidiary of Whirlpool Corporation (“Whirlpool”), values your trust. This Privacy Notice describes how WIN Health will collect, use, and share Personal Information (defined below) in locations where this notice is posted, including on websites and apps (each, a “Website” or “App”). By using a Website, or App (each, a “Service”), you acknowledge the collection, use, and disclosure of your information as described in this Privacy Notice.
SUMMARY OF KEY PROVISIONS:
I. INFORMATION WE COLLECT INCLUDING OUR USE OF TRACKING TECHNOLOGIES
1. Information you provide directly to us
You may provide your Personal Information in a variety of situations, including when you sign up for a WIN Health Labs account, contact us, sign up to receive communications from us, purchase a product or service, submit your product registration, submit a customer service request, enter a sweepstakes or contest entry, provide us feedback or survey responses, or otherwise use any of the Services. Personal Information you provide may include:
- Contact information, such as your name, email address, mailing address, social media information, phone number, etc.
- Billing and payment information, such as your credit card number and billing address
- WIN Health Labs, LLC account information, including your user name, account number, and password
- Product and ownership information and purchase history
- Preferences, such as product wish lists, order history, and marketing preferences
- Feedback about our products and services
- Other information that you choose to share with us
We also may give you the option of submitting Personal Information, such as email address, of other individuals so we can send them invitations to use the Services.
2. Usage Information.
WIN Health Labs, LLC, our business partners, and our service providers may use technologies that collect information about how you interact with our Services, emails, advertising, and content (“Usage Information”). Usage Information may include: (i) your device ID and IP address, which is a unique set of numbers assigned to your computer by your Internet Service Provider (ISP); (ii) the type of browser and operating system you use; and (iii) other information about your online session, such as the URL you came from to get to our Websites and the date and time you visited our Websites or used our Apps.
The technologies used to collect Usage Information include but are not limited to:
We use both session ID cookies and persistent cookies:
- A session ID cookie expires when you close your browser. We use session cookies to make it easier for you to navigate our Websites.
- A persistent cookie remains on your hard drive for an extended period of time. We set a persistent cookie to store your account settings so we can identify you the next time you visit or enable some functions on our Websites. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our Websites.
Our Websites may allow you to manage your cookie preferences by clicking on the Do Not Sell My Info link that may be in the footer of those websites. Your Internet browser may also provide you with the ability to delete cookies. If you limit or reject cookies, your ability to use our Websites may be limited.
Web Beacons.Web beacons (also known as “clear GIFs” or “tracking pixels”) are tiny electronic image files that can be embedded within a web page or included in an e-mail message, and are usually invisible to the human eye. When used in our web pages, web beacons may tell us such things as: how many people are visiting our Websites, whether they are one-time or repeat visitors, which pages they viewed and for how long, how well certain online advertising campaigns are converting, and other similar usage data. When used in our e-mail communications, web beacons can tell us information such as the time an e-mail was opened, if and how many times it was forwarded, and what links users click within the e-mail. Based on this information, we can adjust the content, products, services, and promotions we provide you to better meet your interests, and make you aware of Whirlpool products, services, and offers in which you may be interested.
3. Information Provided From Other Parties
We may receive Personal Information about you from our vendors and other third-party sources, including commercially-available sources, social media platforms, and providers of third-party products or services, and combine thisPersonal Information with other Personal Information that we have collected. We may also receive information from other- parties’ products or services that you connect to the Services.
We may de-identify or aggregate Personal Information to create Other Information. We use Other Information for a variety of purposes, including to understand our customers and improve our products and services.
II. HOW WE USE INFORMATION:
We use your information for our business purposes. For example, we use your information to operate and improve our products and services, understand your interests, respond to your requests or questions, confirm and fulfill your order, provide customer service, provide product maintenance and troubleshooting, verify your requests, manage security and prevent fraud or criminal activity, send you marketing communications, and for other purposes we may notify you of from time to time.
II. HOW WE USE INFORMATION
Personal Information.We use Personal Information to provide, support, and improve our products and services, to operate, maintain, and improve the Services, for troubleshooting and maintenance (including for warranty purposes), to better understand how our Services are used, to communicate with you about your account or appliance (including for product service and warranty issues), to conduct surveys, to administer and evaluate your eligibility for offers and promotions, for research and development, to verify requests made pursuant to this Privacy Notice, for security purposes, and, if necessary, prohibit or restrict access to our Services. We also use Personal Information to send you marketing communications and offer you products, services, and customized offers from our various brands and from selected other parties. For example, we may send you a notification when your Smart Appliance needs to be replenished with a refill or replacement item and may direct you to a third-party business partner from which you can purchase that item. We may also provide you with customized offers, such as warranties or accessories, based on your use of the Services. We may also use your Personal Information to better understand what products and services interest you.
We may also use your Personal Information in other ways we notify you about at the time we collect your Personal Information. In Canada or where otherwise required by law, we will obtain your consent for marketing activities.
Other Information.We may use Other Information for any purpose, unless prohibited by law. Where Other Information is combined with Personal Information, we will treat this combined information as Personal Information as long as it stays combined.
III. DATA SHARING:
We may share your Personal Information with our affiliates, our service providers, our business and marketing partners, to comply with laws, to protect ourselves or enforce our rights, in connection with a business transfer, or in other situations where we provide you with notice. Cookies and tracking technologies are used on our Services, which allows us, advertising networks, social media companies, and other providers to place or display ads relevant to you on our Services, as well as on other websites, apps, services, or devices you may use. Otherwise, we will only share Personal Information with unaffiliated parties for their direct marketing purposes with your consent.
III. DATA SHARING
We may share Other Information with other parties for any purpose, unless prohibited by law. We may also share your Personal Information in the following circumstances:
- With Our Affiliates.We may share your Personal Information with Whirlpool’s family of affiliated companies and brands.
- With Our Service Providers and Vendors.We may share your Personal Information with our service providers and vendors to allow them to provide services (such as data analysis, marketing, surveys, data hosting, information technology, payment or loan processing, customer support, warranty services, advertising services, email delivery, and auditing).
- With Business and Advertising Partner.With your consent, we may share your Personal Information with other parties to allow them to send you marketing communications including about their own products and services. Cookies and tracking technologies are used on our Services, which allows us and advertising networks, social media companies, and other providers to place or display ads relevant to you on our Services, as well as on other websites, apps, services, and devices you may use.
- Public Posts.When you post comments or content (such as reviews or recipes) on message boards, blogs, or other interactive features in connection with our Services, your name, city, state, and additional information may be viewable by others. Be careful when deciding to make any of your Personal Information available through the Services. If you use any social media features offered through the Services, such as a Like button, share button, or other features, these features may collect your information, such as your IP address or which page you are visiting, and may set cookies to enable the features. Your interactions with these features are governed by the privacy policies of the social media platforms.
- With Other Users of the Smart Appliance.If you choose to allow others to connect to your Smart Appliance or accept an invitation to connect to another user’s Smart Appliance, the Smart Appliance’s other users may be able to view information related to your usage. If you sell or give away the Smart Appliance, we may share Other Information related to that smart appliance with the new owner (for example, total number of cycles that the Smart Appliance has run).
- Business Transfer.We may disclose Personal Information or Other Information in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
IV. INTEREST-BASED ADVERTISING:
IV. INTEREST-BASED ADVERTISING
Some of our Websites may also allow you to manage your cookie preferences by clicking on the Do Not Sell My Info link that may be in the footer of those websites.
Your browser may offer you a “Do Not Track” option, which allows you to signal your preferences to certain website operators that you do not want them to track certain of your online activities. However, our websites do not support Do Not Track requests at this time.
Please note that even if you choose to remove your information or opt-out, you will still see advertisements while browsing online. However, the advertisements may be less relevant to you and your interests.
V. YOUR RIGHTS:
You may opt-out of receiving marketing messages from us by contacting our Privacy Office or by using the unsubscribe link in our emails. You may correct your information or delete your account using the account settings on this Website or App.
If you are a California resident, you have the right to request access to certain information we collected about you, request deletion of your Personal Information (subject to certain exceptions), and request to opt-out of the “sale” (as defined under California law) of your Personal Information.
V. YOUR RIGHTS: CHOICE & ACCESS
Your Right to Opt-Out. You may inform us that you do not want WIN Health Labs, LLC to use your Personal Information to provide you with offers or send you newsletters, emails or other marketing communications, by sending your request using the information in the Contact Us section of this Notice (below). You may also unsubscribe from receiving promotional communications from a Whirlpool brand by clicking on the unsubscribe link provided in that brand’s promotional emails. However, please note that you cannot opt-out from all communications, as WIN Health Labs may need to send you information related to our products (for example, warranties or service reminders), your orders, or your accounts.
You may also use the contact information below to withdraw your previous consent to share your Personal Information with other parties (other than our service providers), or to request removal of your Personal Information from our message boards, blogs, or other interactive features on our Websites. In some cases, we may not be able to remove your Personal Information, in which case we will let you know why.
Your Ability to Review/Correct.You may review, correct, or update your Personal Information by contacting us, or if you are a registered user, through your account settings. After your account is deleted/terminated, your information may not be deleted in its entirety from our systems. We may retain backup copies of your information, including to assist with any legal obligations, resolve disputes, and enforce our agreements. We will retain your information for as long as necessary to fulfill the purposes of processing described in this Notice. Keep in mind that we may have multiple accounts for you, and updating or deleting one account may not update or delete all of them — for example, your website account may differ from your App account.
California Residents: Your California Privacy Rights.If you are a California resident, California’s Shine the Light law permits you to request and receive information about disclosure of certain of your Personal Information to other parties for their direct marketing purposes. It is our policy not to share Personal Information (as defined in California’s Shine the Light law) with unaffiliated parties for their direct marketing purposes without your consent. Please note that our brands are part of Whirlpool and are not unaffiliated parties for purposes of this Privacy Notice.
California residents also have the right to make the following requests. We will not discriminate against you because you exercise any of these rights.
- Access– You can request that we disclose to you the categories of Personal Information we collected about you, the categories of sources from which we collected the Personal Information, the categories of Personal Information we sold or disclosed, our business or commercial purpose for collecting and selling your Personal Information, the categories of third parties with whom we shared your Personal Information, and the specific pieces of Personal Information we collected about you over the past 12 months.
- Deletion– You can request that we delete your Personal Information that we maintain about you, subject to certain exceptions.
- Opt-out– You can request to opt-out of the sale of your Personal Information by either clicking the Do Not Sell My Info link that may be in the footer of our websites, or contacting us using the information provided in the Contact Us section, below. For purposes of this Privacy Notice, “sell” means the transfer of your personal information to a third party for monetary or other valuable consideration. WIN Health Labs is a common business for purposes of the California Consumer Privacy Act. Your opt-out of cookie-based tracking for advertising purposes is specific to the device, website, and browser you are using, and is deleted whenever you clear your browser’s cache.
California residents can make an access or deletion request by contacting us using the information in the “Contact Us” section of this Privacy Notice (below), or by calling toll-free or using the web form available in the Contact Us section on our websites.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the Personal Information and whether you have an account with us. If you designate an authorized agent to make a request on your behalf, please ensure the authorized agent identifies him/herself as an authorized agent.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
We also want our California residents to know the following:
- We collect and use the following categories of Personal Information for the business and commercial purposes described in this Privacy Notice: Identifiers; contact and payment information; characteristics of protected classifications under California or federal law (such as age and gender); commercial information; internet or other electronic network activity information; geolocation data; audio, electronic or visual information; and inferences. We collect this Personal Information from the sources described above.
- We disclose each of these categories of Personal Information for our business and commercial purposes as described in this Privacy Notice.
VI. DATA SECURITY:
We take reasonable steps to protect your information, but please be aware that no transmission of information over the Internet is 100% secure.
We are committed to maintaining the security of the data you provide to us. We use reasonable organizational, technical, and administrative measures designed to protect Personal Information that we store. We also seek to use third-party service providers capable of protecting the information they maintain or process for us. Unfortunately, no data transmission over the internet or storage system can be guaranteed to be 100% secure. If you have any security concerns (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us using the information in the “Contact Us” section below.
VII. SERVICES FROM OTHER PARTIES:
Our Services may contain links to websites or apps owned by other companies. We recommend that you carefully review their privacy notices.
Our Services may contain links to websites owned by other companies. Because Whirlpool has no control over the privacy practices or content of these linked sites, we recommend that you carefully review the privacy notice of each website you visit. This Privacy Notice does not address, and we are not responsible for, the privacy or other practices of any other parties.
VIII. UPDATES TO THIS PRIVACY NOTICE
Please review the “Effective Date” at the top of this page to determine when this Notice was last revised.
We may occasionally update this Privacy Notice. Please review the “Effective Date” at the top of this page to see when this Privacy Notice was last revised. If we make any material changes we will notify you as required by law, which may include by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Your use of the Service(s) following these changes means that you acknowledge the revised Privacy Notice.
You may contact us by email at firstname.lastname@example.org, or by mail at Chief Privacy Officer, Whirlpool Corporation / WIN Health Labs, LLC, 2000 N. M-63, MD 2533, Benton Harbor, MI 49022 U.S.A. You may also contact us using the toll free number or web form available on the Contact Us page of our websites.
XI. CONTACT US
If you have any questions about this Privacy Notice, please contact us by email at email@example.com, or please write to us at the following address:
Chief Privacy Officer
Whirlpool Corporation / WIN Health Labs, LLC
2000 N. M-63
Benton Harbor, MI 49022
We try to respond to general privacy inquiries within 30 days or as otherwise required by law. Requests to opt-out from our marketing will be processed within 10 business days.