Date of Last Revision: July 1, 2014
I. Personally Identifiable and Other Information We Collect
II. Use of Information Collected
III. Information Sharing and Disclosure
IV. Choice and Opt-Out
V. Changing Your Information
VII. Links to Other Sites
VIII. Bulletin Boards/Chat Rooms
X. Contact Information
I. Personally Identifiable and Other Information We Collect
We collect information from Users of the Web Site.
A. Information About Our Users
The minimum age to register for the Services is 13 years old. WD-40 Company does not knowingly collect PII from children under the age of 13. Children under the age of 13 should not provide any information on the Web Site. We ask that parents supervise their children while the children are online.
Users may wish to request information about our company or our products, to become a member of our Fan Club, to participate in our Services (such as contests, offers, and surveys), or to submit suggestions, photos, videos, and other information to us. In connection with each of those items you may be asked to provide information that could identify you personally, such as your name, company, title, phone (including mobile phone) number, email address, mailing address, and/or credit card number. In addition, if you wish to register for certain Services, download certain information, or upload information like photos and videos, you may be required to provide certain additional information that can identify you personally, such as your Member Name or username, your password, contact information, occupation, workplace, hobbies, interests, age, marital status, education, and children, and other information. Users are responsible for maintaining the confidentiality of any passwords they are given to access our Web Site, and are fully responsible for all activities that occur under their passwords. Information that you voluntarily provide that is not required by us is provided by you in your sole discretion.
If you are a registered User under 18 years of age (but at least 13 years of age, which is the minimum age to register for the Services) (a “Minor”), you may request and obtain removal of content you post to our Web Site by using the Contact Us form on our Web Site and stating your specific needs. Removal of such content, however, does not ensure complete or comprehensive removal of the content or information posted on the Web Site. For example, the content or information may remain on our servers in some form even though not visible to other Users of the Services or the public, or, even though the content or information is no longer visible to other Users of the Services and the public, it remains visible because a third party has copied the posting or reposted the content or information originally posted by the registered Minor. We are not responsible for third parties that copy or repost your content. We will deliver notice by e-mail to any Minors, of which we are actually aware, who are registered Users of our Web Site of such User’s right to request and obtain removal of content posted by such User to our Web Site, instructions on how such User may request and obtain removal of such content, and notice that such removal may not be comprehensive. All members of the Fan Club, including Minors, can, at any time, themselves remove any content they have posted. The removal of content is not required in some circumstances, including where the content is posted by a third party, where we anonymize the content, where the registered Minor received consideration for providing the content, where the registered Minor failed to properly follow the instructions requesting removal of the content, or where any other provision of federal or state law requires us or any of our third party providers to maintain the content or information.
B. Aggregated Data
WD-40 Company compiles anonymous, aggregated statistics from Users for a variety of internal and marketing purposes. Such purposes include benchmarking, determining appropriate levels of hardware, determining the numbers of employees that will be needed to provide the Services to our Users, and reporting numbers of Users and/or web sites that use the Services. This anonymous, aggregated data is not used in any way that can identify an individual person or User.
C. Web Site Viewing Information
The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the web site of your browser’s manufacturer. If you disable your web browser's ability to accept cookies, you will be able to navigate our Web Site, but you will not be able to successfully use certain of the Services or all portions of the Web Site or functionality of the Services.
2. Log Files
As is true of most web sites, we gather certain information automatically and store it in log files. This information does not identify individual Users. Log files include internet protocol ('IP') addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and click stream data. We use this information to analyze trends, to administer the Web Site, to see how Users move around the Web Site, and to gather demographic information about our User base as a whole. We do not link this automatically-collected data to PII. We collect certain anonymous information from your visit to the Web Site via industry standard and commercially available web analytics solutions, including Google Analytics.
3. Clear Gifs (Web Beacons)
We use clear gifs (a.k.a. web beacons) that help us better manage content on the Web Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web Users. In contrast to cookies, which are stored on a User's computer hard drive or mobile device, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers' PII. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see "Choice and Opt-Out."
Third party applications (such as widgets) created by third party developers may also be available on the Web Site. Third party applications are small bits of software, often with interactivity, that can be installed into Users' profiles or shared with other Users. However, WD-40 Company does not control the third party developers, and cannot dictate their actions. When a User engages with a third party application, that User is interacting with the third party developer, not with WD-40 Company. WD-40 Company encourages Users not to provide PII to the third party's application unless the User knows the party with whom it is interacting.
4. Do Not Track Signals
Your browser should provide you with an option to turn on “do not track” (DNT) signals, which directs the browser to signal web sites when loading to block the web site from collecting data from you. Our Web Site does not obey browser DNT signals.
We may receive information about your location from your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices provide users with the ability to turn off or disable location services. Most likely, these controls are located in the device's settings menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or your device manufacturer. Our Web Site’s graphical user interface is customized to your device regardless of how you interact with us, online, mobile, or in any other manner. In certain circumstances, however, unless you are on a computer, it’s possible that due to the interoperability requirements of certain devices, you will not be able to successfully use certain of the Services or all portions of the Web Site or functionality of the Services.
II. Use of Information Collected
WD-40 Company uses the information you provide to us to give you access to information you request and to perform the Services. WD-40 Company may also use the information that you provide to us to contact you to further discuss your interest in our company and our Services, and to send information regarding our company or partners (such as marketing promotions and events). We store any voluntarily provided email we receive for archival purposes and for our own marketing purposes if we feel that it is consistent with the nature of the inquiry. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect and the need to fulfill your request. This allows us to provide you with a personalized experience regardless of how you interact with us – online, mobile, or in any other manner. This information is not shared with third parties for their own use, unless you specifically authorize such sharing.
While WD-40 Company does not itself currently collect credit card information, but we may do so in the future. If we do collect credit card information in the future, the sole purpose of the collection and use of that information will be to effect transactions for the sale of products. Currently, however, any purchases through our Web Site are not handled by us but are handled by a third party, as described in Section III.B. below.
To locate other Users that you may already know in the physical world, we allow Users to search for registered Users using certain PII (i.e., full name or email address). WD-40 Company also allows Users to browse for certain non-PII information to help connect with other Users (e.g., hobbies or interests). We may also enable Users to publicly display some PII if they choose to do so. Search engines may index the portion of a User's PII that is voluntarily publicly displayed by a User. If you have consented to receive promotional materials (e.g., newsletters) or notifications from us, we may periodically use your e-mail address to send you such materials related to the Services. If you want to stop receiving such materials from us you can change your profile settings under "Profile." In addition, you can opt out of, or unsubscribe from e-mails at any time by following the instructions contained in those e-mails.
Non-PII information you provide to us in response to: (i) multiple choice questions like "Hobbies and Interests" and "Employment"; (ii) information you add to open-ended questions; and (iii) other non-PII about you, may be used to customize the online ads, mobile messages, special promotions, mobile coupons, e-mails, and other marketing information you encounter to those we believe are aligned with your interests. For example, based on your hobbies we might display an advertisement about one of our products that you may not be familiar with, or about an event that you may be interested in. The information used for this feature does not provide your PII or identify you as an individual to third parties. If you would like to disable advertising customization for these types of information, please visit "Profile" under the Fan Club.
III. Information Sharing and Disclosure
A. Non-Personally Identifiable and Aggregated Information
As described elsewhere in this Policy, we may customize the advertising and marketing messages you receive through the Web Site, or may work with outside third parties to do so. Your non-PII may be shared with these companies so this customization can be accomplished and to improve the effectiveness of our Web Site and mobile experience regardless of how you interact with us, online, mobile, or in any other manner. Anonymous click stream, number of page views calculated by pixel tags, and aggregated demographic information may also be shared with WD-40 Company's advertisers, mobile marketing providers and business partners.
We may also perform statistical analyses of User behavior and characteristics in order to measure interest in and use of the various areas of the Web Site. In addition, we may in the future inform advertisers and mobile marketing providers of such information as well as the number of Users that have been exposed to or clicked on their advertising banners. We will, however, provide only aggregated data from these analyses to third parties.
We do not link aggregate User data with PII.
B. Personally Identifiable Information
We share PII with third parties in particular situations.
We may in connection with the Web Site use the services of third party technology consultants and CRM vendors, who may, in the course of providing services to us, be given access to the information you have provided to us. Each of these service providers is contractually obligated to provide services to us in a manner consistent with this Policy.
WD-40 Company employees, agents and contractors must have a business reason to obtain access to your PII. WD-40 Company may share your PII with those who help us manage or provide the Services (e.g., message board administration, statistical analyses, data processing, and order fulfillment), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfillment aspects of contests and promotions.
These outside contractors or agents may temporarily store some information on their servers, but they may only use your PII to provide WD-40 Company with a specific service and not for any other purpose. WD-40 Company may also provide your PII to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your PII. WD-40 Company also may share your PII with companies that are affiliated with WD-40 Company if we have a business reason to do so.
If in the future we intend to share personally identifiable information with third parties acting other than as our agents or service providers, we will provide you with the opportunity to opt-out prior to the sharing.
C. Agents and Service Providers
We use a credit card processing company when necessary to bill for products and services. This company does not retain, share, store or use PII for any other purposes.
We use other third parties to provide shopping services, and a community environment/social network, on our Web Site. When you sign up for the Services we will share the PII that is necessary for the third party to provide the Services.
D. Law Enforcement and Assignment
We reserve the right to disclose your PII pursuant to a subpoena or other judicial or administrative order, when required by law, when we believe that disclosure is necessary to protect our rights, the rights of our affiliated companies, the rights or safety of any individual or the public, and rights of our Users or any third party. In addition, if WD-40 Company sells all or part of its business, makes a sale or transfer of all or a material part of its assets, or is otherwise involved in a change of control, merger or transfer of all or a material part of its business, WD-40 Company may transfer your PII to the party or parties involved in the transaction as part of that transaction.
IV. Choice and Opt-Out
We provide you the opportunity to "opt-out" of having your PII used for certain purposes, when we ask for this information. For example, if you sign up for the Services but do not wish to receive any additional marketing material from us, you can so indicate your preferences in your Profile.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication. You may also update your profile on the sites that contain a profile and change your newsletter and promotional communications' preferences.
You will be notified when your personal information is proposed to be collected by any third party that is not our agent or service provider, so you can make an informed choice as to whether or not to share your information with that party.
V. Changing Your Information
Users and Customers may update or change their PII by editing their Profile. To update or delete User information on the WD-40 Fan Club web site please login to www.mywd40.com with your WD-40 Company Member Name and password.
VI. Third Party Advertisers
On both our Web Site and third-party web sites, we display interest-based advertising using information you make available to us when you interact with our Web Site, third-party web sites, or our content or Services. Interest-based ads, also sometimes referred to as personalized or targeted ads, are displayed to you based on information from activities such as purchasing WD-40 products through Amazon.com, visiting sites that contain WD-40 content or ads, or using our payment services, like Checkout by Amazon.
Advertisers and other third-parties (including the ad networks, ad-serving companies, mobile marketing providers and other service providers) may assume that users who interact with or click on a personalized ad, mobile message or content are part of the group that the ad, mobile message or content is directed towards (for example, users in the Southwest (U.S.A.) who bought or browsed for vintage car accessories). Also, some third-parties may provide us information about you (such as the sites where you have been shown ads or demographic information) from offline and online sources that we may use to provide you more relevant and useful advertising.
We do not provide any personal information to advertisers for such purposes or to third party web sites that display our interest-based ads. As further explained in the Amazon.com Privacy Notice here, however, Amazon.com may use PII or allow third parties to use PII to personalize and display advertisements on that web site. If you do not want Amazon.com to use personal information that it gathers to allow third parties to personalize advertisements displayed to you, you may opt out by adjusting your Amazon.com Preferences. You will still see ads but they will not be personalized. Please visit Amazon.com’s Advertising Preferences page to learn how to set this preference.
We offer you choices about receiving interest-based ads from us and certain of our third-party partners. You can also generally opt-out of receiving personalized ads from third party partners, advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. See NAI opt-out page or the DAA opt-out page.
The security of your PII is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology ("SSL").
We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
VIII. Links to Other Sites
Our Web Site may contain links to other web sites. WD-40 Company is not responsible for the privacy practices or the content of non-WD-40 Company Web Sites. Non-WD-40 Company linked Web Sites are not under the control of WD-40 Company and WD-40 Company is not responsible for the contents of any such linked sites, any link contained in such linked sites, or any changes or updates to such sites. WD-40 Company is not responsible for any transmission received from any non-WD-40 Company Web Sites or mobile applications including any webcasting or other method of transmission. Links to non-WD-40 Web Sites are provided only as a convenience. WD-40 Company does not endorse any link made available through our Web Site that is not a WD-40 Company Web Site. We encourage all users of our Web Site to read the privacy policies of each and every Web Site visited when linking directly from our Web Site.
This Policy applies only to information collected by the Web Site regardless of how you interact with us – online, mobile, or in any other manner.
IX. Bulletin Boards/Chat Rooms
If you use a bulletin board or chat room on the Web Site, you should be aware that any PII you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the PII you choose to submit in these forums.
In addition, if you provide to WD-40 Company directly, or you choose to post on the portions of the Web Site that are viewable by others, any comments, ideas, or suggestions that are accompanied by your name (which is PII), or your first name and your last name initial, WD-40 Company may use both your comments, ideas, and suggestions, and your name, for our marketing purposes without compensation or acknowledgment of any kind.
XI. Contact Information
WD-40 Company Customer Relations
P.O. Box 80607
San Diego, CA 92138-0607