Culligan Do-It-Yourself Privacy Policy

Effective Date: August 01, 2025

Introduction

This Privacy Policy describes how Culligan International Company (“Culligan,” “we,” “us,” or “our”) collects, uses, and discloses information about individuals who use our website, culligandiy.com, or other services where we may collect Personal Information (collectively, “Services”). For certain Services, we may provide additional notices about our privacy practices. When applicable, please read those additional privacy disclosures to understand how they apply to you.

This Privacy Notice should be read in conjunction with Culligan’s Terms and Conditions, and any other policy, agreement, or terms which may affect your relationship with us. Please read this Privacy Policy and the Terms and Conditions carefully before using our Services. By using our Services or otherwise providing Personal Information to us, you agree to our Terms and Conditions and consent to the collection, use, communication, disclosure, and processing of your Personal Information as described in this Privacy Policy. If you do not agree, please discontinue use of the Services.

Table of Contents

Click on the links to navigate to the sections:

Personal Information We Collect

Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. Personal Information includes “Personal Data” as defined in applicable privacy laws. Personal Information does not include information that is publicly available, de-identified, or aggregated.

We may collect the following Personal Information about you:

·         Contact Information and Identifiers, including name, account name, username, unique personal identifier, online identifier, IP address, email address, physical address, and phone number.

·         Commercial Information, including purchase, payment, and billing information; credit card number, debit card number, and other financial information; records of products or services purchased, obtained, or considered; and other purchasing or consuming histories or tendencies.

·         Demographic Information, including age and birth date.

·         Internet or Other Electronic Network Activity Information, including internet or other similar activity, browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, and social media account information.

·         Geolocation Data, including physical location based on information you provide directly or inferred from your IP address.

·         Audiovisual Information, including audio recordings of customer care calls, video, or similar information.

·         Communications with Us, including the contents of your communications with us via phone, email, text message, or other means (such as survey responses, product reviews, and comments on our blog and social media pages).

The Personal Information we collect about you may not include all of the examples listed above, depending on your interactions with us.

Why We Collect Personal Information

We may use your Personal Information for any purposes not inconsistent with our statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and any purposes not prohibited by applicable law, including the purposes listed below.

We collect Personal Information for the follow purposes:

·         Providing Our Products and Services, including processing orders, transactions, and payments; allowing you to participate in the features we offer; maintaining your accounts; providing you with appropriate products and recommendations; and helping you find relevant products and services.

·         Identifying You, including confirming your identity when signing up to use the Services, verifying your identity to process a transaction, and recognizing you when you use our Services.

·         Communicating with You, including contacting you about our products and Services, your orders, and updates to our terms and policies; obtaining your feedback; confirming your preferences; tailoring our communications to you; and providing customer service and support.

·         Conducting Analytics and Improving Our Products and Services, including understanding and improving our Services, products, marketing, and advertising; providing you with a better Service experience; and performing research and analytics.

·         Serving Marketing and Advertising, including sending you relevant marketing materials and advertisements; showing you relevant ads while you browse the internet or use social media; sending you relevant coupons, discounts, or promotions; and allowing you to participate in our promotions, sweepstakes, and contests.

·         Operating our Business, including performing audits, research, and analysis; maintaining our Services; identifying prospective customers, suppliers, and other vendors; administering our relationships with our customers, retailers, suppliers, and other vendors; fulling purposes that we describe to you at the time we collect your information; in connection with mergers, acquisitions, divestitures, or similar corporate transactions; and otherwise managing our business.

·         Securing our Services and Detecting Fraud, including detecting, identifying, investigating, responding to, and preventing fraud and illegal or malicious activities against you and/or us; protecting our Services; authenticating users of the Service; and monitoring of unauthorized accesses, mitigating risks, ensuring the integrity and confidentiality of your Personal Information, and generally providing a secure experience on our Services.

·         Managing Legal and Compliance, including preparing for and participating in litigation; enforcing our policies and terms; protecting our rights; fulfilling our legal obligations; managing risk, investigations, and reporting requirements; and complying with other legal and regulatory obligations.

How We Collect Personal Information

We may collect your Personal Information through various means, including:

·         Directly From You when you:

o   Register or maintain an account with us.

o   Enter search terms or provide other information through our Services.

o   Subscribe to receive our notifications.

o   Exchange communications with us, including by mail, email, or phone.

o   Post comments to our website or social media pages.

o   Obtain customer service or technical support.

o   Participate in promotional activities.

o   Post reviews or other information about our products or Services.

o   Connect with us via social media.

·         Automatically Through Your Use of Our Services through cookies and other online tracking technologies, as described in the “Cookies and Other Online Tracking Technologies” section below.

·         From Our Retailers, including when you purchase our products. Retailers provide us information about your system and your Personal Information so we can provide and improve our products and Services and otherwise operate our business.

·         From Our Parent, Subsidiary, and Sister Companies, including to provide our Services and operate our business.

·         From Our Vendors that help us operate our business and collect Personal Information on our behalf, including software and website vendors.

·         From Other Parties, including business partners, resellers, and data brokers, some of which may sell the information to us. To understand your rights and choices regarding Personal Information collected by other companies, please consult the privacy policies of the businesses that you interact with. We are not responsible for the privacy policies or privacy practices of other parties.

Cookies and Other Online Tracking Technologies

Culligan and/or our vendors may automatically obtain certain information about you through cookies and other online tracking technologies (collectively, “Cookies”) when you access or use the Services (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network-connected hardware (e.g., computer or mobile device); the domain name of the website that allowed you to navigate to our Services; search engines used; the length of time spent on our Services; the pages you looked at on our Services; the address (or “URL”) of the websites you visited before and after visiting our Services; the frequency of your visits to our Services; and other Internet or Other Electronic Network Activity Information.

In general, our Services use Cookies as follows:

·         Where necessary to run our Services, including allowing you to log in.

·         To optimize the functionality of our Services, including by personalizing content for you, greeting you by name, and remembering your preferences (e.g., your choice of language or region).

·         For analytics purposes, including helping us understand how our Services are used, seeing what products are the most interesting to visitors, enhancing our web experience, and improving our product marketing.

·         For purposes of ad targeting and marketing, including collecting information about your browsing behavior on our Services and showing you interest-based advertising when you visit other websites or use social media.

·         To determine if you open or act upon our email messages. Information on unsubscribing from our commercial email communications is provided below.

·         To obtain information about your interactions with our online advertisements, including understanding when an ad was clicked and the website where the ad was seen.

·         For device and activity monitoring purposes, including confirming identity, maintaining security, preventing fraud, troubleshooting, tracking and/or improving our Services, and customizing or optimizing experiences on our Services.

We may generally identify your location from your IP address for purposes such as verifying your location (e.g., for shipping), or restricting/providing content based on your location. Our Services may also be personalized based on your general location so we can provide you with more location-relevant content.

In certain circumstances, we may collect information to help us analyze activity on our Services, as applicable, through session replay technologies to help us understand and analyze how visitors use our Services, and to improve the Services. These technologies may collect the following types of information, among others: IP address; screen size; device type (unique device identifiers); browser information; geographic location; and preferred language.

See below for more information on your choices regarding Cookies.

How We Disclose Personal Information

We may disclose your Personal Information for any purposes not inconsistent with this Privacy Policy, our written statements at the point of collection, or applicable law. In general, we disclose Personal Information as follows:

·         With Our Related Entities, including with our affiliates, subsidiaries, locations, brands, and other related entities so that those entities may assist us in providing the Services to you, align business strategies, and develop new products and services.

·         With Our Agents and Retailers, in order for them to provide their services to us. For example, we may disclose your Personal Information to provide customer service, operate our business and Services, provide our products and Services to you, install our products, including at your location, manage our Services, help run our promotions (including coupons and rewards programs), process payments, perform auditing and quality control, communicate with you, and otherwise operate our business.

·         With Our Vendors, Consultants, Service Providers, and Other Business Providers that help us provide the Services and otherwise run our business, including website hosting, data storage, analytics and reporting, and customer support providers.

·         With our Marketing Providers and Business Partners for co-marketing purposes, to improve our products and Services, for marketing and communication purposes, to facilitate our marketing campaigns, or to provide you with other products and Services that may interest you.

·         With our Advertising Partners for the purposes of ad targeting, remarketing, and other advertising; providing you with promotional material that may be of interest to you; and customized advertising.

·         With our Insurers and Professional Advisers for the purposes of managing risks, obtaining professional advice, and exercising or defending against legal claims.

·         For Legal and Compliance Purposes, including to comply with any legal process; to respond to requests from public and government authorities; to enforce our Terms and Conditions and policies; to safeguard our operations; to enforce and protect our rights, privacy, safety, or property, and/or those of you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.

·         With Potential Acquirers in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

Social Features on Our Service

Certain functionalities on our Services permit interactions that you initiate between our Services and certain other services, such as social networks (“Social Features”). Examples of Social Features include: (a) enabling you to send content such as contacts and photos between the Service and another’s service; (b) “liking” or “sharing” Culligan’s content; and (c) otherwise connecting our Services to another service (e.g., to pull or push information to or from our Services). If you use Social Features, information you post or provide access to may be publicly displayed by the social media service that you use. Similarly, if you post information on a social media service that references the Services (e.g., by using a hashtag associated with Culligan), your post may be used on or in connection with the Services or otherwise by Culligan and/or our affiliates. Both Culligan and the social media service may have access to certain information about you and your use of the Services and any social media service.

Your Choices about Tracking and Communications

Cookies and Tracking Technologies

Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please review your browser’s Help menu for instructions, or visit www.allaboutcookies.org for more information. Please note that if you disable all Cookies, some features of our Services may not function properly.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

Analytics and Advertising Technologies

We also use analytics and advertising services provided by Google. We may use first-party Cookies or other first-party identifiers as well as third-party Cookies or other third-party identifiers to implement Google advertising features, such as delivering advertisements, measuring your interests, and personalizing content. For more information on how Google Analytics uses data collected through our services, visit www.google.com/policies/privacy/partners. To opt out of Google Analytics Cookies, visit tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.

In addition, we may serve ads on other online services that are targeted to reach people on those services who are also identified in one of more of our databases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our databases and the databases of the other online services such as Facebook/Meta. We are not responsible for these services, including without limitation the security of the data they hold about you. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, to find out what options Facebook offers you to control such ads.

Culligan is not responsible for the effectiveness of any other parties’ opt-out options or the accuracy of their statements regarding their programs.

Email Communications

You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.

Text/SMS Messages

You may opt in to receiving text messages and alerts on the mobile phone number(s) you provide to us. If you opt in, we may send you text messages (a) regarding your account; (b) about our products and promotions (including advertisements, sales, and special offers); (c) to investigate or prevent fraud; and (d) to alert you in the event of an issue with any of your purchases. You do not have to opt in to text messages and alerts to use and enjoy our Service or products. If you opt in, standard text messaging charges may apply. You may choose to opt out from our text messages and alerts at any time.

Security and Passwords

We take commercially reasonable measures to protect Personal Information from loss; theft; misuse; and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and electronic storage are not completely secure, and Culligan cannot guarantee the security of your Personal Information. You are responsible for maintaining the secrecy of any credentials used to access your account with us. If you suspect any unauthorized activity associated with your account, please report that activity to us immediately.

Age Restrictions

Our Services are not intended for children under eighteen (18) years of age. Culligan does not knowingly collect Personal Information of individuals under eighteen (18) years of age. If we learn that we have collected Personal Information of a person under eighteen (18) years of age, we will dispose of that information, or otherwise treat it, in accordance with applicable laws and regulations.

Data Retention

We will store your Personal Information for no longer than is necessary for the performance of our obligations, to achieve the purposes for which the Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.

International Transfers

We are a United States company and we provide our Services subject to United States law. If you are accessing the Services from outside the United States, your Personal Information will be processed in the United States or other countries. We may transfer information to our affiliates, vendors, and business partners around the world, subject to applicable laws, and as a result Personal Information may be transferred to, processed, and stored in states, territories, countries, and other jurisdictions that are outside the jurisdiction where you are located. As such, courts, law enforcement, and authorities in other countries may, in certain circumstances, be entitled to access your Personal Information. By using the Services or providing us with any information through the Services, you consent to this potential transfer, processing and storage of your information, and you acknowledge that other countries, territories, and jurisdictions may not provide the same privacy protections and their privacy laws may be different than those in the United States or in the country where you are located.

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect technological advancements, legal and regulatory changes, good business practices, or otherwise at our discretion subject to applicable laws. If we make any changes, our posted Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth at the top of the Privacy Policy.

Your continued use of the Services after we make changes to this Privacy Policy is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Contact Culligan

If you have any questions about this Privacy Policy, please contact Culligan via email at CAPrivacyRequest@culligan.com, or by calling us toll-free at (877) 225-8757.

Additional U.S. State Privacy Notice

This section supplements other parts of this Privacy Policy and provides additional information for residents of certain states that provide privacy rights to consumers (each, a “Covered State”), including pursuant to the California Consumer Privacy Act (“CCPA”). If you are a resident of a Covered State, you may have the right to submit certain requests relating to your Personal Information, as described below.

Targeted Advertising and Sales

We may share your Personal Information for cross-context behavioral advertising or targeted advertising (“Targeted Advertising”). Although we do not sell Personal Information in exchange for money, some of the ways in which we disclose Personal Information for advertising may be considered “sales” in some Covered States. To opt out of sales and Targeted Advertising, please email us at CAPrivacyRequest@culligan.com.

Listed below are the categories of Personal Information we disclose for purposes of Targeted Advertising or otherwise “sell” or “share” as defined under applicable privacy laws. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.

Categories of Personal Information:

·         Contact Information and Identifiers

·         Personal Information described in Cal. Civ. Code § 1798.80(e)

·         Internet or other electronic network activity information

·         Geolocation Data

Categories of Third Parties to which Information was Sold or Shared for Targeted Advertising:

·         Advertising companies

·         Analytics companies

·         Social networks

Purposes for Selling or Sharing for Targeting Advertising:

·         For marketing, advertising, certain types of analytics, or similar purposes

·         To show you relevant ads while you browse the internet or use social media

Making a Privacy Rights Request

If you are a resident of a Covered State, you may have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please email us at CAPrivacyRequest@culligan.com or call us at (877) 225-8757. To opt out of sales and sharing, please see the Targeted Advertising and Sales section above. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you may be asked to log into your account or to provide additional pieces of Personal Information that we will match against our records.

Residents of Covered States may have the following privacy rights:

Right to Know and Access. You may have the right to confirm whether we are processing your Personal Information; to access your Personal Information; and to obtain certain information about our processing of your Personal Information, including the categories of Personal Information we have collected about you, the specific pieces of Personal Information we have collected about you, and information about recipients to which we disclose Personal Information.

Right to Data Portability. You may have the right to obtain a copy of Personal Information you provided to us in a portable format.

Right to Correct. You may have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.

Right to Delete. You may have the right to request that we delete your Personal Information, subject to exceptions.

Right to Opt Out of Sales and Targeted Advertising. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for Targeted Advertising.

Right to Opt Out of Automated Decision-Making and Profiling. Culligan does not engage in automated decision-making or profiling in furtherance of decisions that produce legal or similarly significant effects. Culligan will accommodate applicable rights under the CCPA related to automated decision-making technology, as applicable.

Right to Appeal. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If you are a resident of a Covered State whose privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request by emailing us at CAPrivacyRequest@culligan.com or calling us at (877) 225-8757.

If you choose to exercise any of your privacy rights, we will not discriminate against you.

Please note that if you make a privacy rights request, we will retain the Personal Information submitted in connection with your request for recordkeeping purposes.

Additional Disclosures for California Residents

Personal Information We Collect. We also process the following categories of Personal Information about California residents:

·         Personal Records as described in Cal. Civ. Code § 1798.80(e), including telephone number, credit card number, debit card number, physical address, or any financial information.

·         Inferences About You from Any Other Category of Information We Collect, including information reflecting your preferences, characteristics, trends, or attitudes.

California Employees and Job Applicants. If you are a California employee or current or former California employee/contractor, a separate California privacy notice will be provided to you in the course of your employment. If you are a California job applicant, please review our California Job Applicant Privacy Notice. If you are a California resident and you believe you interacted with us in a different capacity, or if you have any questions, please email us at CAPrivacyRequest@culligan.com.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not collect, use, or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

California “Shine the Light”. We do not share Personal Information with third parties or affiliates for those other parties’ own direct marketing purposes. Californians may request information about our compliance with this law by emailing us at CAPrivacyRequest@culligan.com.