Water Cooler Group, LLC
Last Updated: January 8, 2020

Water Cooler Group (WCG) LLC, a Delaware limited liability company (“WCG”, “we”, “us”, or “our”), has adopted this privacy policy (“Privacy Policy”) because we know that you care about how information that we collect from you, and information you provide to us, is used and shared.  This Privacy Policy applies to any and all information that you submit to us in connection with your access to and/or use of our website (the “Website”).  This Privacy Policy also describes the types of information we collect from you through the Website, how we use and process that information, and our legal basis for doing so.  It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.  Please read this Privacy Policy carefully prior to your use of the Website.  If you do not agree to this Privacy Policy, do not use or continue to use the Website.

By accessing and using the Website, you are deemed to have read, accepted, executed and be bound by this Privacy Policy, including, without limitation, the information collection, use and disclosure practices described herein.  This Privacy Policy is governed by the Website Terms of Use , which includes all disclaimers of warranties and limitations of liabilities.  All references to WCG in this Privacy Policy shall include all of WCG’s parents, subsidiaries, affiliates, and brands.  Capitalized terms that are used but not defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Use.

Information We Collect and Receive

In order for us to (i) provide you with the services and functionalities offered via the Website, (ii) engage in troubleshooting activities, (iii) respond to your inquiries, and (iv) improve upon the Website’s performance, safety and security, we may collect and process some or all of the following types of information about you through the means discussed below.  Please note that we may need certain types of information so that we can provide certain services offered on the Website to you.  If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use certain services on the Website.

  • User-provided Personal Information.  Information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, including, without limitation, information you provide us when you correspond with us in connection with information requests or other communications initiated by you in regards to WCG’s products and services, such as your name, physical address, email address and/or telephone number (“Personal Information”).  For example, this includes the email you provide us when you submit an inquiry through our contact form on the Website and any other Personal Information we may request from you in order to respond to your inquiries and answer your questions.  Any Personal Information that we collect is passed on to the applicable department (e.g., new business, human resources, press communications) for follow-up or to provide any information you have requested.
  • Usage Information Automatically Collected.  Information that is not Personal Information, but that relates to your usage of the Website or that is necessary for the proper functioning or improvement of the Website, including:  (i) times and dates and the extent of your usage of the Website; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Website; (iii) device keyboard settings; (iv) content you view, follow, and otherwise interact with; (v) usage history such as areas and pages within the Website that you access or use and/or which buttons in the Website you click on; (vi) search terms you type in on the Website; (vii) the URL or advertisement that may have referred you to the Website; (viii) the search terms you entered into a search engine that may have led you to the Website; (ix) the mobile platform or service provider you use, and (x) other device and Website access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token (collectively, “Usage Information”).
  • .  Information about you that we may receive from third parties.  For example, we may supplement certain information that we collect from you with outside records, or third parties may provide us with information about you in connection with a separate agreement entered into with such third party.  We use this information to supplement the information we collect about you in order to provide more relevant, safer experiences for you with the Website and improve the Website and analytics. If we combine or associate information from other sources with information that we collect through the Website, we will treat the combined information in accordance with this Privacy Policy.

While certain types of information described above, such as Usage Information and Third-Party Information, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Website, as described above.  If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information.

Cookies and Other Tracking Technologies

We may use cookies, for example, to keep track of your use of the Website to better enhance the efficiency and effectiveness of the Website and certain services and functionalities offered thereon.  Cookies are also used to collect general usage and volume statistical information that does not include Personal Information.  We may also use another company or third-party service to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about users of the Website.  For information about what cookies are, how they work, how we use them, and how to remove them, please read the remainder of this section below.

What is a Cookie?

Cookies are small pieces of information that are stored as text files by your Internet browser on your computer’s hard drive.  Most Internet browsers are initially set to accept cookies.  You can set your browser to refuse cookies from websites or to remove cookies from your hard drive, but if you do so, you may not be able to access or use portions of the Website, or certain offerings on the Website may not function as intended or as well.  Also, some browsers have “do not track” features that allow you to tell a website not to track you.  These features are not all uniform.  If you block cookies, certain features on the Website may not work. If you block or reject cookies, not all of the tracking described herein will stop.  Please note that certain options you select are browser- and device-specific.

What Cookies do we use?

A more detailed list of the cookies we currently, or in the future may, use and how we use, or may use, them are as follows:

  • Analytics and Research:  We use certain cookies and other technologies also help us to understand, improve, and research features and content on the Website.
  • Performance:  We use performance cookies to help us route traffic between servers and understand how the Website is performing so we can provide users with the best experience possible.
  • Security:  We secure the Website with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Use, such as unauthorized access or activity.
  • Website Features and Services:  We use certain cookies to provide greater functionality to the Website and help us deliver our products and services.

Web Beacons

Our Website may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Website is used.

We may use third parties to gather information about how you and others use the Website.  For example, we will know how many users access a specific page and which Website Content they clicked on.  We use this aggregated information to understand and optimize how the Website is used.

Do Not Track Requests

Your browser may give you the ability to control cookies, which may depend on the type of cookie, and browsers can be set to reject browser cookies.  However, blocking or deleting cookies may prevent you from using most of the Website, or certain features, functionalities and/or services contained therein.

Some browsers have settings may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit.  These features are not all uniform and there is no consensus among industry participants as to what “Do Not Track” means in this context.  If you block cookies, certain features on the Website may not work.  If you block or reject cookies, not all of the tracking described here will stop.  Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.  Note that certain options you select are browser- and device-specific.

How We Use the Information We Collect

We may use the information we collect about/from you to:

  • Identify you and potentially improve and/or customize the Website
  • Send you requested information regarding our products and services
  • Address inquiries and respond to your requests for information, questions and comments, including communications initiated by you via our Website contact forms
  • Obtain your views of our products, services and activities
  • Identify trends, conduct data analysis and determine the effectiveness of our marketing and promotions and other service offerings
  • Maintain security
  • Enforce our Terms of Use and applicable law
  • Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection

We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud or other criminal activity.

We may also ask for your consent to process your Personal Information for a specific purpose that we communicate to you.  When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time, and we will stop processing of your data for that purpose.

How We Share the Information We Collect

We may share aggregated usage information and may otherwise disclose non-Personal Information that we collect to third parties.  However, absent your prior consent, we will share your Personal Information with third parties only in the ways that are described in this Privacy Policy, including as set forth below, and we do not otherwise sell your Personal Information to third parties.

  • We may use third parties to outsource one or more aspects of our business and/or Website operations (such as employment opportunity listings and job application services, data processing, web analytics, maintenance, and security execution and clearing services), in which case, we may provide such third parties with, or give such third parties access to, your Personal Information in connection with the performance of such activities.  Such third parties will only use your Personal Information to the extent necessary to perform their functions and will be contractually bound to process your Personal Information only on our behalf and in compliance with our requests.
  • Our service providers may collect certain information about your visits to, and activity on, the Website as well as other websites or services, they may set and access their own tracking technologies on your device (including Cookies and Web Beacons).  Some of these parties may collect Personal Information when you visit the Website or other online websites and services.  We may also share certain non-Personal Information with these parties, in connection with the services they provide to us.
  • In the event that we undergo re-organization, are sold to or merged with a third party, or sell all or substantially all of our assets, any Personal Information we hold about you may be transferred to that re-organized entity or third party in compliance with applicable law.
  • In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.
  • We will also share your information with any member, subsidiary, parent or affiliate of our corporate group, only for the purposes set out above, to assist in the improvement and optimization of the Website, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes.
  • In addition to the foregoing, we also reserve the right, and you hereby authorize us, to share or disclose (including, without limitation, to law enforcement agencies, public authorities, governmental departments, or other similar organizations) information we collect, including your Personal Information, and any other information, records or electronic communications of any kind, when we determine (in our sole discretion), that the disclosure of such information is necessary to identify, contact, or bring legal action against you if:
    • you are or may be violating the Terms of Use or this Privacy Policy, or if otherwise necessary to enforce our Terms of Use or other policies governing the Website;
    • you are interfering with our or any third party’s rights or property;
    • you are violating any applicable law, rule or regulation;
    • necessary or required by any applicable law, rule or regulation, including a subpoena or similar legal process or request/order;
    • necessary or required for purposes of public importance, to protect our rights, protect your safety or the safety of others, investigate security, technical issues or fraud, or respond to a government request; and/or
    • requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency;
    • necessary to support any audit, or to comply with similar corporate governance functions; or consented to by you.

Email Notifications and Opt-Out

We want to communicate with you only if you want to hear from us, such as in response to a request for information.  We maintain a strict “no-spam” policy.  Unless you specifically opt-out as provided herein, by accepting the Terms of Use and this Privacy Policy, you expressly agree that we may use your information to contact you by email in order to deliver you information that is relevant to your use of the Website or certain requests for information you have asked for via communications with us through the Website, such as administrative notices, service enhancements, information regarding our products and services, “newsletters”, or that, in some cases, is targeted to your interests, such as service/functionalities offerings that we believe you may be interested in learning more about.  You may choose to stop receiving these email communications from us by following the unsubscribe instructions at the bottom of any email from us.

Link to Third Party Websites

The Website may include links to other websites, mobile applications or services (“Third Party Sites”), whose privacy practices may differ from those set forth herein.  Such links are not an endorsement by Company of those Third Party Sites and/or the products or services they offer.  If you visit Third Party Sites or submit Personal Information to any of those Third Party Sites, your visit and Personal Information is governed by their privacy statements.  We encourage you to carefully read the privacy statement of any Third Party Site you visit, as it may differ substantially from that of this privacy statement.  Company makes no representations or warranties with respect to, nor is Company responsible for the privacy policies of, any Third Party Sites.  If you decide to click on any such links or access any Third Party Sites appearing on the Website, you do so at your own risk.

Storage of Information

All information, including Personal Information, collected by us is stored on servers and systems located in the United States, which servers are licensed, owned, and/or maintained by WCG.  We make no representation or warranty with respect to any duty to permanently store any information you may provide or that we otherwise collect about you.  We strive to keep our processing activities with respect to your Personal Information as limited as possible.  In the absence of specific retention periods set out in this Privacy Policy, we will retain the information we collect from or about you only as long as necessary to provide you with the Website or our services, which includes for the duration of, but could extend beyond, your active participation on the Website, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal and/or statutory obligations, resolve disputes, enforce our agreements, and protect our legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.  By using the Website and providing us with information (including Personal Information), you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties.  We may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.  This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Website.

Your Rights Regarding Your Information

In certain circumstances you have the right to access the Personal Information that we hold about you and to correct, update, or request deletion your Personal Information.  Prior to the fulfilment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request.  Even after you request that we delete your Personal Information, we may retain certain information as required by law or as necessary for our legitimate business purposes.

More specifically, you have the following rights:

  • The right to require free of charge (i) confirmation of whether we process your Personal Information and (ii) access to a copy of the Personal Information retained;
  • The right to request proper rectification, removal or restriction of your Personal Information;
  • Where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);
  • Where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
  • The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and
  • The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.

As far as we process your Personal Information on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis herein. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.

Security

The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Although we will do our best to protect your Personal Information, we cannot guarantee the security of your information transmitted through the Website or in your written communications to WCG; any transmission is at your own risk.

We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such information confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete and absolute security of any Information collected, stored or used by us cannot therefore be guaranteed.  In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.  If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately.

California Users

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.  As explained elsewhere in this Privacy Policy, we will not sell or transfer your personal information to third party companies for their direct marketing purposes without your consent.  California customers who wish to request further information about our compliance with this statute or who have questions more generally about our Privacy Policy and our privacy commitments to our customers and Website users should not hesitate to contact us at the address or phone number below.

Updates to this Privacy Policy

We may change the terms of this Privacy Policy at any time in our sole discretion.  Whenever we make a material change, we will post such change on the Website or send you an email.  The effective date of the most recent version of this Privacy Policy will appear at the top of this page.  New versions of this Privacy Policy will never apply retroactively.  We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.  Once a change becomes effective, your use or continued use of the Website shall automatically constitute your acceptance of such changes.

Contact

If you have any questions or complaints regarding WCG’s privacy practices and/or this Privacy Policy or want to exercise your rights to access, review, correct, delete or object to the processing of your information, please contact us via regular mail or at the email address below.  WCG’s Legal Department is responsible for the organization’s compliance with this Privacy Policy.

Sending an email request to: privacy@watercoolergroup.biz

Regular mail, postage pre-paid to:

Water Cooler Group LLC
99 Washington Street

South Norwalk, CT 06854
ATTN: Privacy