WD-40 COMPANY LIMITED WEBSITE PRIVACY & COOKIES STATEMENT
Last reviewed 18 May 2018
WD-40 Company Limited of Brick Close, Kiln Farm, Milton Keynes, MK11 3LJ with company registration number 01755958 (“WD-40 Company Limited”, “we”, or “us”) operates this website (the “Website”). We take the privacy of those visiting the Website (“you”) very seriously. We are committed to complying with data protection legislation which regulates the processing of your personal information and grants you various rights in respect of this information.
What does this statement cover?
This Privacy Statement (the “Statement”) describes how we use the personal information we collect from, or which is supplied to us by visitors to the Website, including personal information we obtain when we offer services through the Website (the “Services”). You may only use our Services if you are over 16.
We provide this Statement because you have the right to know what information we collect about you, how it is protected and used, and the circumstances under which it will be disclosed. The Statement also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out at section 11 below.
We reserve the right to modify this Statement at any time. If we make material changes to this Statement, we will notify you of this either by email or by means of a notice on the Website; where necessary we will obtain your consent.
This Statement explains how we use personal information that we collect from, or which is supplied to us by, Users of our Website.
We collect and process personal information about you when you interact with us and our Website, and when you purchase goods from us and use our Services. This information includes:
We use data about Users to compile anonymous, aggregated statistics for operational 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 that use the Services. This anonymous, aggregated data is not used in any way that can identify an individual User.
We use the information you provide to us for the following purposes:
We share your personal information within WD-40 Company and with group companies which are involved in carrying out the processing described above. We may use personal information relating to you to customise the advertising and marketing messages you receive on the Website, or may work with outside companies to do so. Aggregated data may be shared with these companies so this customisation can be achieved. Anonymous click stream, number of page views calculated by pixel tags and aggregated demographic information will also be shared with our advertisers and business partners.
We also use data regarding your visit to the Website to perform statistical analysis in order to measure interest in, and use of, the various areas of the Website. We share such information with relevant advertisers or external parties. We will, however, provide only aggregated data from these analyses to third parties, not specific Users’ data.
Personal information will be shared with third party service providers (including technology consultants and CRM vendors), who, in the course of providing services to us, will be given access to the information you have provided to us and will process it on behalf of WD-40 Company for the purposes identified above. Such third parties include providers of website hosting, maintenance, and technology and CRM services. Each of these service providers is contractually obliged to provide services to us in a manner consistent with this Statement.
Our employees, agents and contractors must have a business reason to obtain access to your personal information. We share also your personal information with those who help us manage or provide the Services (e.g. message board administration, statistical analyses, data processing, and order fulfilment), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfilment aspects of contests and promotions. These outside contractors or agents will only use your personal information to provide us with a specific service and not for any other purpose.
If, in the future, we wish to share your personal information with third parties acting other than as our agents or service providers, we will tell you about this and provide you with the opportunity to opt-out.
In the event that the business is sold, integrated with and/or transferred to another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Your personal information will be disclosed where disclosure is necessary in order for us to comply with a legal obligation or is otherwise necessary in order for us 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.
From time to time, we would like to send you by email information about other similar WD-40 Company products or services which we think will be of interest to you (including, for example, newsletters and promotional communications). We will do this only if you agree and you have a right to object to receiving this information from us, or profiling we carry out for direct marketing, at any time. You can do this by:
We do not transfer your personal information to countries outside the European Economic Area (the “EEA”) except with WD-40 Company in the USA (self-certification under EU-US Privacy Shield pending). However, if this changes, we will tell you.
We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure.
We follow generally accepted industry standards to protect personal information submitted to us by Users, 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.
There are two types of cookies: session and persistent. Session cookies disappear from your computer when you close your web browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. If you have chosen to identify yourself to us then we use session cookies containing encrypted information to allow us to uniquely identify you.
We use persistent cookies that only we can read and use to identify browsers that have previously visited the Website. When Users provide us with identifiable information about themselves, a unique identifier is assigned to them. This unique identifier is associated with a persistent cookie that we place on the User’s web browser. We are very careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website.
We use the following cookies:
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for, such as remembering your login details or shopping basket items, cannot be provided.
These cookies collect anonymous information on how people use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
These cookies remember choices you make such as the country you visit our Website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Social Media Cookies
These cookies allow you to share what you’ve been doing on the Website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.
As is true of most websites, 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 clickstream data. We use this information to analyse trends, to administer the Website, to see how Users move around the Website, and to gather demographic information about our User base as a whole. We do not link this automatically-collected data to your personal information. We collect certain anonymous information from your visit to the Website via industry standard and commercially available web analytics solutions, including Omniture Web Analytics.
Clear Gifs (Web Beacons)
We use clear gifs (a.k.a. web beacons) that help us better manage content on the Website 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, clear gifs are embedded invisibly on web pages and are about the size of the full-stop at the end of this sentence. We do not link the information gathered by clear gifs to Users’ personal information. 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 section 4 below.
The Website contains links to other websites over which we have no control. We are not responsible for privacy policies or practices of other websites to which you choose to link from this site. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.
You should be aware that if you upload comments, ideas, suggestions, product reviews and/or end user content together with your name or initials to parts of the Website that can be viewed by other Users, or you provide this kind of information directly to us, we will use your comments, ideas, and suggestions, and your name, for our marketing purposes.
If you change your mind and no longer wish your information to be used in this way you should contact us using the contact details at section 13 below.
Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in the future.
Where we process personal information in connection with performing a contract or Service, or for a competition or as otherwise necessary to service you as a customer, we keep the information for five (5) years (unless otherwise required by local law) from your last interaction with us.
You have a right to ask us for a copy of your personal information. You also have the right to ask us to correct, delete or restrict (stop any active) processing of your personal data, and to obtain the personal data you provide to us for a contract or with your consent in a structured, commonly used and machine readable form, and to ask us to share (port) this data to another data controller.
You have the right to object to the processing of your personal information by us in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person or breach the privacy rights of others, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the contact details at section 13 below. If you have unresolved concerns, you have the right to make a complaint to the data protection supervisory authority where you live, work or where you believe a breach may have occurred.
You do not have to supply us with any personal information in order to visit the Website. If you use our Services we will ask you to supply us with information. When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the services you wish to access and whether the supply of any information we ask for is optional. If you choose not to provide the information, you may not be able to use some Services.
To change or update the information we hold and which relates to you please contact us, using the contact details at section 13.
WD-40 Company Limited is the data controller of your personal information. If you have any questions about this Statement, please contact us at firstname.lastname@example.org