Bonney Plumbing, LLC Privacy Notice and Policy

EFFECTIVE DATE: July 25, 2023

This Bonney Plumbing, LLC (“Bonney” or “we”) Privacy Notice and Policy (“Policy”) describes how Bonney collects, uses, discloses and otherwise processes the personal information described in this Policy, as well as the rights and choices you have regarding your personal information.

For information about the privacy choices you have regarding your personal information, review Section 7. Your Privacy Choices below. If you are a resident of California, please refer to Section 12. Additional Information for California Residents below for information about the categories of personal information we collect and your rights under California privacy laws.

Your use of our Services (defined below), and any dispute over privacy, is subject to this Policy and any additional terms and conditions that may be provided by Bonney to under your engagements with Bonney.

Table of Contents

Scope
Personal Information Collected
Purposes of Use and Processing
Disclosures of Personal Information
Aggregate and Deidentified Data
Cookies, Targeting, and Analytics
Your Privacy Choices
Children/Minors
Security
Changes to this Policy
Contact US
Additional Information for California Residents

1. Scope

Except as noted below, this Policy applies to the personal information that we process about you both online, through this website: www.bonney.com, as well as offline, such as when we make a service call or when you contact our customer service department (collectively, our “Services”). Representative examples of when this Policy applies include:

When you visit our website;
When you use the services through our website, such as creating an account or scheduling a service call;
When you use products or services that we offer that include this Policy;
When you register for or participate in our webinars and other events;
When you subscribe to our newsletters and marketing/advertising communications;
When you participate in sweepstakes, surveys and research conducted by us; and
when you communicate with us or otherwise engage with us related to our Services.

This Policy does not apply to the personal information that we collect and process about Bonney employees and personnel or job applicants and candidates.

2. Personal Information Collected

As further described below, we collect personal information directly from you, from other persons, and automatically when you use our website.

Personal Information Collected Directly. The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes:

Registration and profile information. When you register for an account or create a customer profile with us, we collect certain personal information from you, such as your name, address, and phone number, as well as any personal information you submit to us through your account.
Payments and purchases. When you make a purchase or payment through the Services, we collect purchase and payment information to process your payment, such as your credit card number and applicable billing address. We also maintain records about past Services we have provided to you.
Communications and interactions. When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records of communication and information that you post on our social media channels and information you provide to us related to any customer support requests.
Promotions. If you participate in promotions that we offer, we may collect your name, email address, and other registration information related to and the promotion.
Other requests. We also collect personal information related to other requests that you submit to us related to our Services. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests.

Personal Information from Other Sources. We may collect personal information about you from other sources, such as public databases, joint marketing partners, social media platforms or other persons/entities.

Lead Generation: We may receive lead and prospect information, including email and postal mailing address, from lead generation services about prospective customers that may be interested in our Services.
Social Media: If you post information about us or engage with us on social media, we may collect personal information about you from that platform or account. These platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
Your Employer: your employer may provide us with contact information to contact you when we reach your location to provide our Services or for billing or other purposes.

Personal Information Collected Automatically. We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Section 6. Cookies, Targeting and Analytics, below.
Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, items viewed, and time spent within the Services.
Location information. We may collect or derive location information about you, such as through your IP address.

3. Purposes of Use and Processing

Generally, we collect, use, disclose and otherwise process the personal information we collect for the following purposes:

Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you about the Services, and for similar service and support purposes.
Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes.
Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, including about third-party products and services we think may interest you, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
Bonney Beyond Membership program. If you have a Bonney Beyond Membership, we use your personal information to administer that program, including to provide the Bonney Beyond Limited Warranty, to offer service discounts, and to provide priority scheduling, pre-scheduled maintenance, and cleaning visits.
Research and surveys. To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
Security and protection of rights. To protect the Services and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions.
Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, record keeping, and legal functions.

4. Disclosures of Personal Information

We may disclose the personal information that we collect for the purposes described above, to provide our Services to you, to respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and as follows:

Affiliates. Where we are unable to provide you with the requested service, then services requested, then, with your consent, we may provide your personal information to an affiliate who is able to provide you with the services you have requested.

Vendors and service providers. We may disclose personal information we collect to our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, payment processors, analytics providers, consultants, auditors and legal counsel.

Our business customers. Any data that we collect and process on behalf of a business customer will be disclosed to the business customer and otherwise shared as directed by that business customer.

Social Networks We may disclose or make available personal information to platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests.

Advertising networks: We may also make certain information that includes personal information available to ad networks in support of our marketing, analytics, advertising and campaign management (see Section 6. Cookies, Targeting and Analytics for more information).

Data analytics providers. We may share certain information with data analytic providers in order to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content.

We also may share your personal information in the following circumstances:

In support of business transfers. If we are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. We may also share certain personal information as appropriate prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as we deem appropriate to plan for a transaction, as well as to evaluate a potential transaction.

Compliance and legal obligations. We may also disclose personal information to entities to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.

Security and protection of rights. We may disclose personal information where we believe doing so is appropriate to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms and Conditions. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, record keeping, and legal functions.

5. Aggregate Data and Deidentified Data

We may also use and disclose aggregated data sets or deidentified data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.

6. Cookies, Targeting and Analytics

We and our third-party providers and service providers use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect browsing, activity, device and similar information within our Services and to target advertising and content across our Services and nonaffiliated sites and services. We use this information, for example, to analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies and tracking within the Services, as described in this section. For more information on the types of personal information we collect via cookies and similar mechanisms, please see Section Personal information Collected.

Cookies. Cookies are a small text file stored on a user’s device (such as a computer or smartphone) by a website they visit. It is created by the website’s server and sent to the user’s browser, where it is stored for future reference. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service.

Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Analytics and Tools. We use tools, such as Google Analytics, which are operated by non-affiliated companies. These analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-device Tracking. We and our service providers may use the information that we collect about you within our Services and on other non-affiliated sites and services to help us and these service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). This information may be used as set forth in this section.

Targeted Advertising. We work with ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on non-affiliated sites, mobile apps and online services. We may share certain information with these ad companies, and we and they may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on non-affiliated sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these ad companies use this information to provide you more relevant ads and content within our Services and on non-affiliated sites and apps, and to evaluate the success of such ads and content.

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with other entities (i) so that we can better target ads and content to you across non-affiliated sites, platforms and services, and (ii) in some cases, these entities may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns. You can opt out of this type of targeted advertising (also called “sharing” under California law) by managing your cookie preferences as set forth in Section 7. Your Privacy Choices below.

Managing Your Preferences. We make available several ways for you to manage your preferences regarding targeted advertising, matching and cookies within our Services. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us.

Cookie preference manager. You can review or change your preferences for targeting cookies and tags on our websites by adjusting your cookie settings from the notice in the lower left of every page on this website. These settings are browser and device specific.
Browser signals. If our website detects that your browser is transmitting a “global privacy control”—or GPC— signal, we will apply that to opt that browser on your device out of targeting cookies on our website. If you come to our website from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well. See Section 12. Additional Information for California Residents, below, for more information about GPC. Our websites do not recognize or respond to browser “do not track” signals.
Industry ad choice programs. You can also control how participating ad companies use the information that they collect about your visits to our website and those of entities that collect information about you through cookies on our website in order to display more relevant targeted advertising to you. You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool to help control interest-based advertising on apps on your mobile device.

Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or ‘contextual’ ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Services who disable cookies will be able to browse the Site, but some features may not function.

7. Your Privacy Choices

We make available a number of ways that you can manage your privacy choices and submit privacy requests related to your personal information. These include:

Targeted advertising/cookie preferences. As described in Section 6. Cookies, Targeting and Analytics there are several ways that you can manage your preferences for targeting cookies and advertising by us and on our website. You can review or change your preferences for many cookies and tags on our website, other than those that are necessary for operation and functionality, by adjusting your cookie settings and by turning on GPC for your browser. These preferences are browser and device specific. You will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies you may need to reapply these settings.
Other targeting/Custom List and matching. If you would like to opt out of receiving targeted marketing and advertising from us based on custom lists and matching (as described in Section Cookies, Targeting and Analytics), please email us at marketing@bonney.com to adjust your marketing preferences.
Marketing communications. You can opt out of receive marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you, and you can opt out of receiving marketing and other texts from us by replying STOP to any text we send to you.

If you are a California resident, please review Section 12. Additional Information for California Residents below, for specific information about your California privacy rights and how to exercise them.

For more information about our privacy practices and your privacy choices, you may contact us as set forth in Section 11. Contact Us.

8. Children/Minors

Our Services are not designed for children and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information in violation of applicable law, we will delete such information from our systems. If you’re a parent and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Section 11. Contact Us.

9. Security

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

10. Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to Policy https://www.bonney.com/privacy-policy/. If we make material changes to how we collect, use and disclose the personal information we have previously collected about you, we will endeavor to provide you prior notice, such as by emailing you or posting prominent notice on our website or within the Services.

11. Contact Us

If you have questions about this Policy or our privacy practices, you may contact us at info@bonney.com.

12. Additional Information for California Residents

This subsection provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws.

In this subsection, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA.

Categories of Personal Information Collected and Disclosed. While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.

Categories of Personal Information Collected		Categories of Third Party Disclosures
Identifiers	Includes direct identifiers, such as name, alias, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers	Advisors and agents Regulators, government entities and law enforcement Advertising networks Data analytics providers Internet service providers, operating systems and platforms Others as permitted by law
Customer Records	Includes personal information, such as name, contact information, account number, and financial or payment information that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, purchases our services, or enters into an agreement with us related to our services.	Advisors and agents Regulators, government entities and law enforcement Others as permitted by law
Commercial information	Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.	Advisors and agents Regulators, government entities and law enforcement Advertising networks Data analytics providers Internet service providers, operating systems and platforms Others as permitted by law
Internet and electronic network activity information	Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.	Advisors and agents Regulators, government entities and law enforcement Advertising networks Data analytics providers Internet service providers, operating systems and platforms Others as permitted by law
Audio, visual and other electronic data	Includes audio, electronic, visual, thermal, olfactory, or similar information, such as, thermal screenings and CCTV footage (e.g., collected from visitors to our offices) and call recordings (e.g., of customer support calls).	Advisors and agents Regulators, government entities and law enforcement Advertising networks Data analytics providers Internet service providers, operating systems and platforms Others as permitted by law
Profiles and inferences	Including inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behavior, or attitudes.	Advisors and agents Regulators, government entities and law enforcement Advertising networks Data analytics providers Internet service providers, operating systems and platforms Others as required by law
Sensitive personal information	In limited circumstances, we may collect: Social security, driver’s license, or state identification card number	Advisors and agents Regulators, government entities and law enforcement Others as required by law

Sales and Sharing of Personal Information. California privacy laws define a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) certain information, including IP address, identifiers, information about your web browsing and usage of our Services, information about how you interact with our ads, and certain analytic information, with third party data analytics, marketing, and advertising partners. We do so to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content. If we are unable to provide you with the service you have requested, then, with your consent, we may share your personal information with an affiliated entity who is able to provide you with the services you have requested.

We do not sell or share sensitive personal information, about California residents. Nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.

Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources: directly from individuals, advertising networks, data analytics providers, service providers, and data brokers

Purposes of Collection, Use, and Disclosure. As described in more detail in Section 3, “Purposes of Use and Processing” and Section 4, “Disclosures of Personal information” above, we collect, use, disclose, and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you: services and support, analytics and improvement, customization and personalization, marketing and advertising, research and surveys, security and protection of rights, legal proceedings and obligations, general business and operational support, in support of business transfers (e.g., if we are acquired by other company)

Sensitive Personal Information. Notwithstanding the above, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you. We do not use or disclose your sensitive personal information other than as authorized pursuant to section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)).

Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we may retain your profile and account data for as long as you have an active account with us and data related to your transactions with us for as long as necessary to comply with our tax, accounting and record keeping obligations, to administer any applicable warranty programs, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with legal obligations.

California Residents’ Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):

To opt out of sales and sharing. The right to opt-out of our sale and sharing of their personal information.
To limit certain uses and disclosures of sensitive personal information. The right to limit our use or disclosure of sensitive personal information to those uses authorized by the CCPA. Bonney does not collect, use, or disclose sensitive personal information, thus this right is not available to California residents.
Deletion. The right to the deletion of their personal information that we have collected, subject to certain exceptions; provided that in some situations we may be required to retain certain personal information, including but not limited to where we require your personal information to honor warranties, complete a transaction, or to provide the product or service you have requested.
To know/access. The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
Correction. The right to correct inaccurate personal information that we maintain about them.
Non-discrimination. The right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below.

Request to know/access, correct, and delete. California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us online by submitting a request via https://www.bonney.com/privacy-policy/ccpa-opt-out-form/. Alternatively, California residents may submit a request by calling us at 866-411-8151.

We will take steps to verify your request by matching the information provide by you with the information we have in our records. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by using the California Privacy Request Form; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Requests to Opt Out. California residents may exercise their right to opt out of the sale and sharing of their online personal information by managing their cookie preferences by clicking on the cookie icon in the lower left of every page on this website. In addition, our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

California residents may exercise their right to opt out of the sale and sharing of their offline personal information through our California Privacy Request Form

Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at info@bonney.com, and include in your request a current California address and your attestation that you are a California resident.