Effective Date: September 9, 2021
This Telematics Privacy Policy ("Privacy Policy") applies to this web-based portal ("Portal") and the subscription services made available to subscribers through the Portal ("Services") by L.B. White Company, LLC (“LBW” or “we” or “us”). In order to use the Services, you must be in possession of an LBW connected heater with an attached internet connected LINK™ device kit ("Connected Heater"), as well appropriate internet connectivity. The Services are a paid subscription that permit subscribers to monitor Connected Heaters, receive alerts, and review maintenance and usage data about the Connected Heaters.
BY USING THE CONNECTED HEATER AND SERVICES, OR BY CLICKING “AGREE,” YOU ACKNOWLEDGE AND CONFIRM YOUR UNDERSTANDING OF OUR COLLECTION, USE AND DISCLOSURE OF INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU ARE USING THE SERVICES ON BEHALF OF AN ORGANIZATION, YOU CONFIRM THAT YOU HAVE AUTHORITY TO ACT ON BEHALF OF THAT ORGANIZATION.
We may modify this Privacy Policy at any time. All changes will be effective immediately upon posting to the Portal. Material changes will be conspicuously posted on the Portal or otherwise communicated to you.
Please note, different privacy statements and policies apply to your use of LBW's public-facing website and the public-facing websites of LBW's affiliates. See those applicable websites for their respective privacy policies.
“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, such as your name, email address, mailing address or phone number. Personal Information does not include publicly available information.
We collect information (1) when you directly provide it to us, (2) from Connected Heaters, (3) automatically on the Portal, and (4) from third-party sources. Some of the information we collect is Personal Information.
When You Sign-Up for an Account. In order to access and use the Portal and Services, you must first establish an account within the Portal. To create an account you must provide your name, email address, and other information prompted upon creation. This data is used to populate a profile within your account. In some cases, if you are renting the Connected Heater from a third-party rental company, you may use that rental company's account to access the Services. Keep in mind that if you are renting a Connected Heater from a third-party rental company, that rental company has access to your Personal Information and Telematics Data.
To Provide Marketing Communications. If you provide an email address to us, we may send you emails, including marketing emails. We may use third-party providers to deliver communications to you. You may opt-out of marketing emails by using the unsubscribe link in the email or contacting us at marketing@lbwhite.com with “Unsubscribe” in the subject line. Opting out of marketing communications does not opt you out of all communications from us, such as business communications.
When You Provide Feedback. When you provide comments or feedback about our Portal, the content on the Portal, the Services, the Connected Heaters, or our other products or services ("Feedback"), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
If You Have a Business Contract with Us. When a business contracts directly with us for the purchase of our Connected Heaters or access to the Services, we may collect the business contact information of those involved. If you and LBW execute any agreements that address the Portal or Services, those contracts shall control in the event of conflict with this Privacy Policy.
We collect technical data from Connected Heaters related to the monitoring, maintenance, performance, and functionality of such Connected Heaters. “Telematics Data" includes: (i) information and data regarding the use, operation and performance of the Connected Heaters, (ii) information or data related to the location and condition of the Connected Heaters, (iii) equipment statistics about the Connected Heaters, like location/GPS data, hours run, fuel level, output temperature, and (iv) other similar data as described in this paragraph. The Services allow you to view some of this Telematics Data on the Portal.
We may change the scope of the Telematics Data which we collect from time to time as we make modifications to the Connected Heater and the Services.
Telematics Data will no longer be collected from the Connected Heater after the subscription to the Services is no longer active.
Cookies & Other Tracking Technologies.
What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Portal.
What are cookies and web beacons / pixel tags? A cookie is a small text file that our website saves onto your computer or device when you use the Portal that provides us certain information about your activities. Cookies allow the Portal to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
Why do we collect Cookies? We use Cookies to:
What type of information do Cookies collect? The Cookies on our Portal may collect information such as:
We may combine information from Cookies with other Personal Information.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Portal and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Portal that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
First and Third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Portal that you are visiting (i.e. this Portal). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We may not have control over how a third-party uses information collected through third-party Cookies.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Portal. Not all features or functions of the Portal may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Portal.
Google Analytics. We use Google Analytics to collect and process information about your use of the Portal. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Portal.
To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Google Maps. The Portal contains maps provided by third parties and/or service providers for your convenience. LBW and such other parties may collect data about how you interact with the maps. For example, Google may collect usage data on maps embedded on the Portal. Even if you do not interact with the maps, Google may still collect certain information about your interactions with our Portal if you are signed into your Google account when accessing our Portal. Please see Google’s privacy policy for more information.
We obtain data about individuals from various third-party companies and public sources (including rental companies who rent-out LBW products) and we may combine that data with other Personal Information. This enhances our existing data about our users, improves our ability to contact you, and enhances our marketing capabilities.
We may use Personal Information for the following purposes:
As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.
Administration. We use Personal Information for administrative purposes, such as to inform our business strategies and to understand the Portal’s demographics and user preferences.
Portal and Services Management. We use Personal Information for Portal management and to provide the Services, such as troubleshooting problems, improving the content and functionality of the Portal and Services, statistical and other analyses of the Services, and to customize the Portal to you and our users. We may use Personal Information as needed to provide you the Services, such as to send you text or email alerts.
Advertising and Communications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services or programs, to notify you of new features on our Portal or of the Connected Heaters or Services, to notify you of changes to this Privacy Policy, and for other similar communications.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Portal, or to other users of the Portal.
We also may combine Personal Information and Telematics Data, which will be used for the purposes described in this Privacy Policy.
We may use Telematics Data for any of the same purposes as described in the previous section with respect to Personal Information. We may also use Telematics Data to: provide you the Services and information about your Connected Heaters; to improve and maintain the Services and Connected Heaters; to troubleshoot problem's with the Services and Connected Heaters; to provide real-time monitoring of the Connected Heaters; to optimize performance and connectivity, and to manage remote operations of the Connected Heaters; to send alerts and notifications related to Connected Heaters; and to provide high-level analytics regarding the Connected Heaters.
We may share Personal Information and/or Telematics Data with the following parties:
Employees and Affiliates. We may share Personal Information and Telematics Data with our employees and affiliates who have a need to know the information for our business purposes.
Rental Business Partners. If you are renting a Connected Heater from a third-party rental company, that third-party rental company may have access to your account, all information pertaining to your account, and Telematics Data. We also may share Personal Information and Telematics Data with these rental companies pertaining to you and your use of the Services and Connected Heaters. A RENTAL COMPANY'S USE OR YOUR PERSONAL INFORMATION AND TELEMATICS DATA IS NOT GOVERNED BY THIS PRIVACY POLICY, AND LBW HAS NO CONTROL OVER A RENTAL COMPANY'S USE OF YOUR DATA. We advise reviewing your contract with your rental company and that rental company's privacy policy for more information about their collection, use and sharing of your Personal Information and any other data they have access to.
Third-Parties and/or Service Providers. We may share Personal Information and Telematics Data with third parties and/or service providers that provide services for us. For example, we share Personal Information with our vendors that: (a) host and manage the Portal, the Services and the Telematics Data; (b) provide advertising and other marketing services on our behalf; (c) improve the content and functionality of the Portal, Services and Connected Heaters; (d) perform data analysis and statistical analysis; (e) troubleshoot problems with and provide maintenance for the Portal, Services and Connected Heaters; (f) provide email services; (g) provide data processing; and (g) support or provide the security of the Portal, Services and Connected Heaters.
Our service providers that host the Services and Telematics Data may use Personal Information and Telematics Data as necessary to provide those services to us, and to help improve their products and services. They are also permitted to aggregate Personal Information and Telematics Data, and use and share that aggregated data for their business purposes so long as such aggregated data does not identify you.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information and/or Telematics Data: (i) if we believe in good faith we are legally required to disclose that information, (ii) if we are advised to disclose such information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, LBW or any other party.
Professional Advisors. We may share Personal Information and/or Telematics Data with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to LBW.
Change in Ownership. In the event LBW is the subject of a change of control or in the event the Portal or Services changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information and/or Telematics Data to the subsequent owner(s), including as part of the due diligence process.
Other. We may share Personal Information and/or Telematics Data with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
By opting-in to receive text messages, you understand and agree that LBW may:
We may send you texts or calls regarding the Services, Connected Heater and other LBW products and services, such as marketing and other promotional texts. You are not required to consent to this Section in order to receive products or services from LBW and you can opt-out at any time.
By providing us a phone number, you confirm that the phone number(s) are owned and used solely by you (or the company you work for). You agree to promptly notify and update your local rental house when your phone number(s) change. Regarding SMS text messages, you may request your local Rental House remove your phone number from the text area of the program to stop receiving texts. Message and data rates may apply.
We may send you emails to the email address(es) provided relating to your use of the Service, the Connected Heater and our other products and services, including certain marketing and promotional emails. You may opt-out of certain marketing and promotional emails by clicking "unsubscribe" in the applicable emails, but this will not necessarily opt you out of all emails from LBW relating to your use of the Services and Connected Heater. You can message email alerts using your Portal account.
You must notify us if you sell or transfer ownership of the Connected Heater. Do not share your account information with any new owner of the Connected Heater.
LBW may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. LBW is the sole and exclusive owner of such de-identified and aggregated information, including if LBW de-identifies Personal Information so that it is no longer considered Personal Information under applicable laws.
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR A DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF ANY INFORMATION, AND YOU PROVIDE SUCH INFORMATION AT YOUR OWN RISK. LBW DISCLAIMS ALL LIABILITY RESULTING FROM DISCLOSURE OR USE OF PERSONAL INFORMATION.
Sensitive Data. “Sensitive Data” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. We do not knowingly collect Sensitive Data from you. Please do not send us Sensitive Data.
Information from Minors. We do not knowingly collect Personal Information from persons under the age of majority in their place of residence (typically this is 18 years old). Do not send us Personal Information if you are under the age of majority. If you are a parent or guardian and you believe your child provided us with their Personal Information, you may contact us as described in the "Contact Us" section below and request that we delete your child's Personal Information.
LBW provides the Services for use in the United States and Canada. LBW does not guarantee that use of the Services outside of the United States and Canada is available or permitted. If you access the Portal from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions.
The Portal may link to, or be linked to, websites not controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Privacy Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.
To correct or update your Personal Information as it exists in our records, please contact us using the information below or you may update certain information in your account (as available).
The terms in this Section only apply if you are a California resident.
CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by emailing us at link@lbwhite.com.
Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under applicable California privacy laws. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.
WE DO NOT SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES.
The terms in this Section only apply if you are a Canadian resident.
Right of Access. Under Canadian privacy laws you have the right:
We may require that you provide information verifying your identity before we provide this requested information to you. To obtain such information, please email your request to marketing@lbwhite.com
Legal Disclosures and Lawful Requests. We and our Canadian, U.S. and other foreign service providers and affiliates may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
If you have questions or concerns regarding this Privacy Policy, contact us at:
L.B. White Company, LLC ATTN: Marketing 411 Mason Street, Onalaska, WI 54650 marketing@lbwhite.com 608-783-5691
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