2. Types of Information Collected
We may collect personally identifiable information from you including, without limitation, non-public information about you that helps Willoughby identify you, such as first and last name, birth date, business title, employer, email address, employer address, office and home telephone number, mobile telephone number, password, account username, unique device identifier of your devices that connect to or access the Sites, order information, credit card, debit card and other payment information, billing and shipping information, purchasing and transaction history, occupation, preferences, information regarding products you purchase from us or products that you contact customer service about (e.g., serial number, fixture manufacturer, date of installation, place of purchase, etc.), information you provide to us when you register your product online, register in connection with our web or mobile applications, and other information that you provide to Willoughby or that is generated through your use of the Sites or interactions with Willoughby that are not otherwise publicly available.
We also may collect non-personally identifiable information about you, such as information regarding your use of the Sites, your IP address, Sites usage statistics, time stamps, browsing history, general geographic location, product settings, adjustments made to products, type of device you use to connect to the Sites, type of computer operating system you use (e.g., Microsoft Windows, Google Chrome OS, Mac OS, Android or iOS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, and information regarding your Internet location when you see Willoughby’s ads and whether you click on such ads. We also may receive certain aggregated or anonymous information regarding users of the Sites such as the age, gender, occupation, zip code, interests, purchase preferences, and language preferences, as well as information collected through questionnaires and surveys. “Non-personally identifiable information” refers to information that does not personally identify the individual to whom the information relates, such as information that is aggregated by Willoughby or a third party, or information that is not linked to contact information or other personally identifiable information of an individual.
In the event that any of the non-personally identifiable information that we collect about you is maintained, used, or shared in a manner that associates it with your name, contact information, or other personally identifiable information, it will be treated as personally identifiable information. If you are logged into your account on the Sites, information such as the content you access, view, click on, or search for when on the Sites, the devices from which you access such content, and the length of time for which you view same, may become personally identifiable. In such an event, Willoughby will treat such information as personally identifiable information.
3. How We Collect Information
We may collect personally identifiable and/or non-personally identifiable information from you when you:
- Access, use, or browse the Sites;
- Register for an account on the Sites;
- Sign up to receive announcements, emails, or newsletters;
- Contact, communicate with, or otherwise interact with Willoughby or its personnel via email, the Sites, fax, telephone, or by other means whether online or offline;
- Order or request products, literature, services, or other information during your visit to the Sites, via email, fax, or other online or offline means;
- Register your product with us;
- Access, use, or adjust any product settings or functional parameters;
- Make a product warranty claim;
- Register, enroll, or participate in any surveys, questionnaires, promotions, or any other services, events, or activities online or offline sponsored by Willoughby or third parties, or offered in connection with the Sites of Willoughby’s products or services (“Activities“).
By using the Sites, or by submitting your personally identifiable information to Willoughby online or offline, you expressly consent to the storage and processing of your personally identifiable information in the United States in accordance with the laws of the United States, or in other jurisdictions.
We may obtain personally identifiable and/or non-personally identifiable information from third parties such as the owners or operators of the websites or applications where our advertisements appear (some of which may partner with Willoughby or with an advertisement network used by Willoughby), our service providers, affiliates, suppliers, vendors, distributors, Activities partners and sponsors, and other sources (e.g., offline records or publicly available information). We may combine personally identifiable information we collect with information that we obtain from these sources. We will treat any such combined information as personally identifiable information.
Willoughby automatically receives and records non-personally identifiable information on our server logs from your browser as well as through other analysis of the Sites. We also may collect information using cookies, web beacons, pixels, gifs, tags, or similar technologies (“Collection Technology“), or through third parties using similar technologies. Collection Technology may operate as a piece of data stored on your browser or device, or may identify, compile, aggregate, and/or collect information through other means. When you visit the Sites, your web browser may use Collection Technology to better enable you to navigate the Sites during your visit and upon your return. You may use the Sites even if you choose to reject or delete certain Collection Technology. Collection Technology also may be used by some of the other websites for which a link is placed on the Sites.
“Demographics and Interest Reporting” to analyze information regarding the interests and demographics of users of the Sites. We use such non-personally identifiable information in the same manner as we use other non-personally identifiable information as described below.
“Remarketing with Google Analytics” to place ads on other websites directed to people who have visited the Sites.
“Google Display Network Impression Reporting” to report how people’s interactions with our ads relate to their visits to the Sites.
You can opt out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings at: https://myadcenter.google.com.
Applications on mobile devices may transmit information to Willoughby about your location when you request information from the Sites. We may use that information to improve the products and services we provide to you.
4. How We Use Your Information
We may use the information we collect:
- To monitor and analyze information regarding your browsing and viewing preferences and to diagnose problems with the Sites;
- To analyze our user’s demographics, interests, and purchasing practices;
- Fulfill orders, ship and confirm orders, and manage payment collection;
- To plan, improve and administer Activities;
- To process and respond to your product warranty claims, inquiries, and other communications;
- For Sites administration, support and improvement;
- To alert you to new features, terms, Activities, special events, stores, products or services, and other useful information regarding any of the foregoing or Willoughby via email, direct mail telephone, or other means;
- To promote and improve the products and services we offer;
- To send announcements and newsletters, and to provide you with personalized content in connection with the same;
- For the purposes for which you provided the information;
- For fraud prevention, internal operations, legal compliance, and other public purposes; and
In addition to the uses discussed above, Willoughby may use non-personally identifiable information in any manner so long as Willoughby uses such information in its de-identified or aggregated form. These uses may include, without limitation, analysis of trends and how the Sites are used; improving the navigation of the Sites; analysis of the performance of the Sites and diagnosis of problems; analysis and development of advertisements and advertising campaigns; and providing you with special offers and promotions and determining the effectiveness of same.
Willoughby also may use your non-personally identifiable information to present you with targeted content and advertisements (including on third-party websites and applications). Such targeted content and advertisements may include marketing for the Sites, and the products or services of Willoughby or its business and advertising partners. Your non-personally identifiable information also may be used to optimize and determine the effectiveness of content and advertisements, and to analyze interactions with content and advertisements.
Some of our third-party advertisers or display networks may participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising and allow consumers the ability to opt out of targeted advertising based on web activity tracking. For more information regarding the foregoing, please visit http://www.aboutads.info/choices/. Please note that after clicking the link and following the instructions provided therein, even if our third-party advertisers or display networks participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising and you opt out of targeted advertising based on web activity tracking, you still may receive standard advertisements from us and targeted advertisements from third parties. You may need to re-click the link and follow the instructions provided therein if you delete cookies or other Collection Technology or use a different computer, device, or browser.
5. How We Respond To “Do Not Track” Signals
Willoughby does not respond to or alter its practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt-out” setting or feature that may be offered by your browser; however, Willoughby reserves the right to do so in the future.
6. Communications with You
You authorize Willoughby to transmit email or postal mail to you or to telephone you, to respond to your communications, promote our services and administer and provide information to you about Activities. If we send any emails to promote our services, unsubscribe instructions will be included in each such promotional email from Willoughby. Please note that such requests may take up to ten (10) business days to become effective. You may not opt out of receiving communications regarding your dealings with Willoughby, the Sites, or technical information about the Sites.
For the purposes of any applicable law regarding notification of persons whose personal information was, or is reasonably believed to have been, acquired by an unauthorized person, any required notification may, where permitted by law, be made by the use of e-mail, telephone, fax or mail (including a notice printed in an available area of a bill or statement) or by posting a notice on the Sites. The specific means used is up to us, and we will use our best judgment based on the circumstances. Where any notice is to be sent to a specific address or number (such as an e-mail address, physical address, telephone number, etc.), we will use the latest available address in our records. YOU AGREE TO THIS MEANS OF NOTIFICATION.
7. Information Sharing with Third Parties
We also may use and share non-personally identifiable information with other third parties. Additionally, we may take personally identifiable information, de-identify it, and share it in a de-identified or aggregated form with advertisers, business partners, and/or other third parties in order to analyze the Sites usage, demographics, or interests, improve the Sites or Willoughby’s products or services, perform services on the Sites, improve the user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.
The Sites are not directed toward children under 18 years of age nor does Willoughby knowingly collect information from children under 18 on the Sites or offline. If you are under 18, you are not permitted to register for an account on the Sites or to otherwise submit any personally identifiable information to Willoughby. If you provide information to Willoughby through the Sites or offline, you represent that you are 18 years of age or older.
9. Protection of Personal Information
Willoughby uses reasonable administrative, physical, and electronic security measures to protect against the loss, misuse, and alteration of personally identifiable information. No transmission of data over the internet, WI-FI, Bluetooth, or other communication protocol is guaranteed to be completely secure. It may be possible for third parties not under the control of Willoughby to intercept or access transmissions or private communications unlawfully. While we strive to protect personally identifiable information, neither Willoughby nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.
10. Updating Your Information
You are responsible for keeping your information current. You may update your information by contacting us at Willoughby. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Willoughby’s internal reporting, processing, and retention policies and all applicable legal obligations.
11. Notice of Privacy Rights of California Residents
Willoughby has adopted a policy of not sharing your personally identifiable information with third parties for their direct marketing purposes if you request that we do not do so (“Opt-Out Policy“). You may make such a request by sending us an email at email@example.com. When contacting us, please indicate your name, address, email address, and what personally identifiable information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personally identifiable information or for processing this request.
If you are a California resident and have provided personal information to a business without an Opt-Out Policy, you may be entitled by law to request certain information regarding disclosures of personally identifiable information made by such business to third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year (“Disclosure Request“). Such business is not required to respond to more than one Disclosure Request per customer each year, or to respond to requests made by means other than through the contact information designated by the business for such purposes. However, please note that due to Willoughby’s Opt-Out Policy described in the preceding paragraph, we are not obligated by law to provide you with the requested information.
If you are still interested in making a Disclosure Request, please contact us at firstname.lastname@example.org. In the Disclosure Request, specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response, but note that Willoughby is entitled by law to respond to your Disclosure Request by notifying you of your right to prevent the disclosure of personal information pursuant to our Opt-Out Policy.
13. International Visitors
The Sites are hosted in the United States and are intended only for United States visitors. If you are accessing the Sites from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer.