Effective as of July 28, 2009
WD-40 Company ("WD-40 Company", "we", or
"us") takes the privacy of those visiting our web sites ("you") very
seriously. We provide this Privacy Policy (the "Policy") because you
have the right to know what information we collect, how it is protected
and used, and the circumstances under which it may be disclosed. This
Policy describes our use and sharing of personally identifiable
information, which includes your full name, email address, mailing
address, telephone number, or credit card number ("PII") that
you may voluntarily provide to us if and when you register for certain
services. The term "User" refers to visitors and to those who register
for certain services. This Policy applies to the services offered by WD-40 Company on its web sites, including any WD-40 Company-branded web site, the WD-40 Fan Club (www.fanclub.wd40.com), the Money-Saving Tool (www.wd40uses.com), and the WD-40
Job Site (www.wd40jobsite.com) (collectively, the "Web Site"), and any
other features, content, or applications offered from time to time by us
in connection with the Web Site (collectively, the "Services").
I. Personally Identifiable and Other Information We Collect
We collect information from Users of the Web Site.
A. Information About Our Users
The minimum age to register for the Services is 13 years old. WD-40
Company does not knowingly collect PII from children under the age of
13. Children under the age of 13 should not provide any information on
the Web Site. We ask that parents supervise their children while the
children are online.
Users may wish to request information about our company or our products, to become a member of our Fan Club, to participate in our Services (such as contests, offers, and
surveys), or to submit suggestions, photos, videos, and other
information to us. In connection with each of those items you may be
asked to provide information that could identify you personally, such as
your name, company, title, phone number, email address, mailing
address, and/or credit card number. In addition, if you wish to
register for certain Services, download certain information, or upload
information like photos and videos, you may be required to provide
certain additional information that can identify you personally, such as
your Member Name or username, your password, contact information,
occupation, workplace, hobbies, interests, age, marital status,
education, and children, and other information. Users are responsible
for maintaining the confidentiality of any passwords they are given to
access our Web Site, and are fully responsible for all activities that
occur under their passwords. Information that you voluntarily provide
that is not required by us is provided by you in your sole discretion.
B. Aggregated Data
WD-40 Company compiles anonymous, aggregated statistics
from Users for a variety of internal and marketing purposes. Such
purposes include benchmarking, determining appropriate levels of
hardware, determining the numbers of employees that will be needed to
provide the Services to our Users, and reporting numbers of Users and/or
web sites that use the Services. This anonymous, aggregated data is
not used in any way that can identify an individual person or User.
C. Web Site Viewing Information
1. Cookies
WD-40 Company uses cookies to make the Web Site easier
to use and more useful. When you visit the Web Site our servers send a
cookie to your computer. By themselves, cookies do not personally
identify you, but instead simply recognize the web browser you are
using. If you do not otherwise affirmatively provide PII about yourself
to us, either by registering with us, responding to a promotional
offer, or filling out a form, you will remain anonymous to WD-40 Company.
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.
WD-40 Company uses persistent cookies that only we can
read and use to identify browsers that have previously visited the Web
Site. When a User provides us with PII, 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 disable your web browser's ability to accept
cookies, you will be able to navigate our Web Site, but you will not be
able to successfully use certain of the Services.
Some of our business partners (e.g., advertisers) may use cookies on
our Web Site. We have no access to or control over these cookies. See
"Third Party Advertisers."
2. Log Files
As is true of most web sites, we gather certain information
automatically and store it in log files. This information does not
identify individual users. Log files include internet protocol ('IP')
addresses, browser type, internet service provider, referring/exit
pages, operating system, date/time stamp, and clickstream data. We use
this information to analyze trends, to administer the Web Site, to see
how users move around the Web Site, and to gather demographic
information about our user base as a whole. We do not link this
automatically-collected data to PII. We collect certain anonymous
information from your visit to the Web Site via industry standard and
commercially available web analytics solutions, including Omniture Web
Analytics.
3. Clear Gifs (Web Beacons)
We use clear gifs (a.k.a. web beacons) that help us better manage
content on the Web Site by informing us what content is effective.
Clear gifs are tiny graphics with a unique identifier, similar in
function to cookies, and are used to track the online movements of web
users. In contrast to cookies, which are stored on a user's computer
hard drive, clear gifs are embedded invisibly on web pages and are about
the size of the period at the end of this sentence. We do not tie the
information gathered by clear gifs to our customers' PII. We use clear
gifs in our HTML-based emails to let us know which emails have been
opened by recipients. This allows us to gauge the effectiveness of
certain communications and the effectiveness of our marketing
campaigns. If you would like to opt-out of these emails, please see
"Choice and Opt-Out."
Third party applications (such as widgets) created by third party
developers may also be available on the Web Site. Third party
applications are small bits of software, often with interactivity, that
can be installed into Users' profiles or shared with other Users.
However, WD-40 Company does not control the third party
developers, and cannot dictate their actions. When a User engages with a
third party application, that User is interacting with the third party
developer, not with WD-40 Company. WD-40
Company encourages Users not to provide PII to the third party's
application unless the User knows the party with whom it is interacting.
II. Use of Information Collected
WD-40 Company uses the information you provide to us to give you access to information you request and to perform the Services. WD-40
Company may also use the information that you provide to us to contact
you to further discuss your interest in our company and our Services,
and to send information regarding our company or partners (such as
marketing promotions and events). We store any voluntarily provided
email we receive for archival purposes and for our own marketing
purposes if we feel that it is consistent with the nature of the
inquiry. The information is collected and stored in a manner that is
appropriate for the nature of the data that we collect and the need to
fulfill your request. This information is not shared with third
parties for their own use, unless you specifically authorize such
sharing.
While WD-40 Company does not itself currently collect
credit card information, we may do so in the future. If we do collect
credit card information in the future, the sole purpose of the
collection and use of that information will be to effect transactions
for the sale of products. Currently, however, any purchases through our
Web Site are not handled by us but are handled by a third party, as
described in Section III.B. below.
To locate other Users that you may already know in the physical
world, we allow Users to search for registered users using certain PII
(i.e., full name or email address). WD-40 Company also
allows Users to browse for certain non-PII information to help connect
with other Users (e.g., hobbies or interests). We may also enable Users
to publicly display some PII if they choose to do so. Search engines
may index the portion of a User's PII that is voluntarily publicly
displayed by a User.
If you have consented to receive promotional materials (e.g.,
newsletters) or notifications from us, we may periodically use your
email address to send you such materials related to the Services. If
you want to stop receiving such materials from us you can change your
profile settings under "Profile." In addition, you can opt out of, or
unsubscribe from, the No-Rust and other reminder e-mails at any time by
following the instructions contained in those e-mails.
Non-PII information you provide to us in response to: (i) multiple
choice questions like "Hobbies and Interests" and "Employment"; (ii)
information you add to open-ended questions; and, (iii) other non-PII
about you, may be used to customize the online ads, special promotions,
e-mails, and other marketing information you encounter to those we
believe are aligned with your interests. For example, based on your
hobbies we might display an advertisement about one of our products that
you may not be familiar with, or a about an event that you may be
interested in. The information used for this feature does not provide
your PII or identify you as an individual to third parties. If you
would like to disable advertising customization for these types of
information, please visit "Profile" under the Fan Club.
III. Information Sharing and Disclosure
A. Non-Personally Identifiable and Aggregated Information
As described elsewhere in this Policy, we may customize the
advertising and marketing messages you receive on the Web Site, or may
work with outside companies to do so. Your non-PII may be shared with
these companies so this customization can be accomplished. WD-40
Company prohibits these companies from sharing your non-PII with any
third party or from using it for any other purpose. Anonymous click
stream, number of page views calculated by pixel tags, and aggregated
demographic information may also be shared with WD-40 Company's advertisers and business partners.
We may also perform statistical analyses of user behavior and
characteristics in order to measure interest in and use of the various
areas of the Web Site. In addition, we may in the future inform
advertisers of such information as well as the number of users that have
been exposed to or clicked on their advertising banners. We will,
however, provide only aggregated data from these analyses to third
parties.
We do not link aggregate user data with PII.
B. Personally Identifiable Information
We share PII with third parties in particular situations.
WD-40 Company may sometimes permit third parties to offer registration-based services through the Web Site. WD-40
Company is not responsible for any actions or policies of such third
parties and users should check the applicable privacy policy of such
parties when providing PII to them.
We may in connection with the Web Site use the services of third
parties (i.e., technology consultants and CRM vendors), who may, in the
course of providing services to us, be given access to the information
you have provided to us. Each of these service providers is
contractually obligated to provide services to us in a manner consistent
with this Policy.
WD-40 Company employees, agents and contractors must have a business reason to obtain access to your PII. WD-40
Company may share your PII with those who help us manage or provide the
Services (e.g., message board administration, statistical analyses,
data processing, and order fulfillment), or with outside contractors,
agents or sponsors who help us with the administration, judging and
prize fulfillment aspects of contests and promotions.
These outside contractors or agents may temporarily store some
information on their servers, but they may only use your PII to provide WD-40 Company with a specific service and not for any other purpose. WD-40
Company may also provide your PII to a third party in those instances
where you have chosen to receive certain information and have been
notified that the fulfillment of such a request requires the sharing of
your PII. WD-40 Company also may share your PII with companies that are affiliated with WD-40 Company if we have a business reason to do so.
If in the future we intend to share personally identifiable
information with third parties acting other than as our agents or
service providers, we will provide you with the opportunity to opt-out
prior to the sharing.
The information gathering and order processing for theconsumerlink.com/wd40
in the "Shop" section of the Web Site are handled by a third party
vendor, SureSource LLC. They also guarantee not to share your personal
information, and their credit transactions are handled with
industry-standard SSL encryption to protect your information. You can
view their Security information here.
C. Agents and Service Providers
We use a credit card processing company when necessary to bill for
products and services. This company does not retain, share, store or
use PII for any other purposes.
We use other third parties to provide shopping services, and a
community environment/social network, on our Web Site. When you sign up
for the Services we will share the PII that is necessary for the third
party to provide the Services.
These third parties are prohibited from using your PII for any other purpose.
D. Law Enforcement and Assignment
We reserve the right to disclose your PII pursuant to a subpoena or
other judicial or administrative order, when required by law, when we
believe that disclosure is necessary to protect our rights, the rights
of our affiliated companies, the rights or safety of any individual or
the public, and rights of our Users or any third party. In addition, if
WD-40 Company sells all or part of its business, makes a
sale or transfer of all or a material part of its assets, or is
otherwise involved in a merger or transfer of all or a material part of
its business, WD-40 Company may transfer your PII to the party or parties involved in the transaction as part of that transaction.
IV. Choice and Opt-Out
We provide you the opportunity to "opt-out" of having your PII used
for certain purposes, when we ask for this information. For example, if
you sign up for the Services but do not wish to receive any additional
marketing material from us, you can so indicate your preferences in your
Profile.
If you no longer wish to receive our newsletter and promotional
communications, you may opt-out of receiving them by following the
instructions included in each communication. You may also update your
profile on the sites that contain a profile and change your newsletter
and promotional communications' preferences.
You will be notified when your personal information is proposed to be
collected by any third party that is not our agent or service provider,
so you can make an informed choice as to whether or not to share your
information with that party.
V. Changing Your Information
Users and Customers may update or change their PII by editing their Profile. To update or delete User information on the WD-40 Fan Club web site please login to fanclub.wd40.com with your WD-40 Company Member Name and password. To update or delete your information on the WD-40 Job Site please use the Submit Your Trade Secret form and indicate in the Trade Secret box your new information. To update or delete your information on the Money Saving Tool Community please follow the applicable instructions in the applicable section of the Ning Privacy Policy.
VI. Third Party Advertisers
As explained in the Ning Privacy Policy on the Money Saving Tool
Community, Ning may use PII to personalize and display advertisements on
that web site. Ning uses cookies and clear GIFs on that web site,
which allow it to recognize a User's cookie when a User visits that
site.
VII. Security
The security of your PII is important to us. When you enter
sensitive information (such as credit card number and/or social security
number) on our registration or order forms, we encrypt that information
using secure socket layer technology ("SSL").
We follow generally accepted industry standards to protect the PII
submitted to us, both during transmission and once we receive it. No
method of transmission over the Internet, or method of electronic
storage, is 100% secure, however. Therefore, while we strive to use
commercially acceptable means to protect your personal information, we
cannot guarantee its absolute security.
VIII. Links to Other Sites
Our Web Site may contain links to other web sites. WD-40 Company is not responsible for the privacy practices or the content of non-WD-40 Company Web Sites. Non-WD-40 Company linked Web Sites are not under the control of WD-40 Company and WD-40
Company is not responsible for the contents of any such linked sites,
any link contained in such linked sites, or any changes or updates to
such sites. WD-40 Company is not responsible for any transmission received from any non-WD-40 Company Web Sites including any webcasting or other method of transmission. Links to non-WD-40 Web Sites are provided only as a convenience. WD-40 Company does not endorse any link made available through our Web Site that is not a WD-40
Company Web Site. We encourage all users of our Web Site to read the
privacy policies of each and every Web Site visited when linking
directly from our Web Site.
This Policy applies only to information collected by the Web Site.
IX. Bulletin Boards/Chat Rooms
If you use a bulletin board or chat room on the Web Site, you should
be aware that any PII you submit there can be read, collected, or used
by other users of these forums, and could be used to send you
unsolicited messages. We are not responsible for the PII you choose to
submit in these forums.
In addition, if you provide to WD-40 Company directly,
or you choose to post on the portions of the Web Site that are viewable
by others, any comments, ideas, or suggestions that are accompanied by
your name (which is PII), or your first name and your last name initial,
WD-40 Company may use both your comments, ideas, and
suggestions, and your name, for our marketing purposes without
compensation or acknowledgment of any kind.
X. Changes in this Privacy Policy
We reserve the right to modify this Policy at any time, so please
review it frequently. If we make material changes to this Policy, we
will notify you here, by email, or by means of a notice on our home
page. Your continued use of the Web Site after we post a revised Policy
constitutes your acceptance of the new Policy and its terms. If,
however, we materially change our practices regarding the collection or
use of your PII, your PII will continue to be governed by the Policy
that was in place at the time you provided the PII unless we provide
notice to you of the changes in the Policy and you do not object to the
change.
XI. Contact Information
If you have any questions about this Privacy Policy, please contact us at: wd40legal@wd40.com or at the address or telephone number listed below.
Corporate Headquarters
WD-40 Company Customer Relations
P.O. Box 80607
San Diego, CA 92138-0607
USA
Tel: 888-324-7596