Privacy Notice – Colder Products Company

Last Updated: July 6, 2023

Colder Products Company (together with its affiliated, related companies within the Colder Products Company operating company group, the “Company,” “CPC,” “we,” “us,” “our”) respects your individual privacy. This Privacy Policy (“Notice”) sets out how your personal data is used in connection with our Services and when you visit our website, www.cpcworldwide.com (“CPC website” or the “Site”). This Notice applies to personal data processed by us in our business, including on our websites, and other online or offline offerings (collectively, the “Services”) and describes how we collect, use, and share personal data we obtain from users of the CPC website, as well as your privacy rights, including the rights of California residents pursuant to the California Consumer Privacy Act and rights provided under EU and UK law. Before using the CPC website, you should read this Notice.

If you are an employee of CPC, refer to the CPC Employee Privacy Notice. If you intend to apply for a job with us or join our talent network, refer to the Privacy Notice on the Dover Corporation Careers Portal (we are part of the wider Dover family).

By accessing the Services, you acknowledge our collection and use of your personal data as described in this Notice. The provision of the Services are governed by our Terms of Use found at www.cpcworldwide.com/Resources-Support/Privacy.

Who We Are and Contact Details
What Personal Data We Collect: Sources, Purposes, Categories and Lawful Basis
Marketing
Disclosure of Personal Data for business purposes in last 12 months
Security and Confidentiality
How Long Will We Hold Your Personal Data
Transfers of Personal Data
Links to Other Websites
Rights to Your Personal Data
Personal Data of Minors
Cookies
Contact us
Updates to This Notice

1. Who We Are and Contact Details

This is the website of:

Colder Products Company 2820 Cleveland Ave. N., Roseville, MN 55113

You can contact us via e-mail at dataprivacy@colder.com or you can call us toll free at 1-800-444-2474.

2. Personal Data We Collect: Sources, Purposes, Categories and Lawful bases

In the 12 months preceding the date of this Notice, we collect the following personal data in the following circumstances: when you visit our Site and through other interactions with us, when you request information about our Services, or when you voluntarily provide information to us through the Site, or by emailing or telephoning us. We also collect personal data from our social media pages.

The table below sets out what personal data we collect, the purpose of the collection and what lawful basis we rely upon when processing that personal data.

Purpose of processing your personal data	Category of personal data collected	Lawful basis
Delivering our Services and record keeping on our customers or those interested in our services.	Personal identifiers (name, contact details, email address, telephone number).	Our legitimate interest in delivering our Services to you, responding to communications from you in connection with our Services and retaining internal records to evidence (potential) customer interactions.
Direct Marketing such as administering promotions and offers which you register for plus serving online ads.	Personal identifiers (name, contact details, email address).	We will do this with your consent where required by applicable law. Where you are an existing customer, we will rely on our legitimate interest to grow our business where the law permits.
Provide customers visibility to order history, past quotes, and returns.	Commercial information: records of products or Services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.	Our legitimate interest in understanding and improving our business and Services.
Site and Services improvements, network and system security.	Internet or other electronic activity information: information we obtain through your interaction with our Site, including time and date of your visit, IP address, pages visited, length of visit.	Our legitimate interest in improving the products and Services offered through the Site. To conduct internal analysis to understand how many unique visitors visit the Site and to measure the areas of the Site that are of most interest to visitors. Our legitimate interest to protect the security of our systems from adverse events.
Legal and regulatory obligations we have to comply with including requests from public and government authorities.	Personal identifiers (name, contact details, IP address, email address, telephone number).	Compliance with a legal obligation - Where we are required to collect and disclose your personal data because we are subject to a legal or regulatory obligation.
To protect our or a third party's rights and property – defending legal claims, taking legal action.	Personal identifiers (name, contact details, email address, telephone number).	Our (or a third party's) legitimate interests to protect rights and property.

Cookies and Other Technologies

We collect certain information through our use of cookies. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy at www.cpcworldwide.com/Resources-Support/Privacy.

To the extent permitted by applicable law, CPC may also use your personal data as we believe to be necessary or appropriate:

Under applicable law, including laws outside your country of residence;
To comply with legal process;
To respond to requests from public and government authorities including public and government authorities outside your country of residence where strictly required, necessary and proportionate;
To investigate and resolve complaints, grievances or misconduct allegations;
Health and safety purposes;
Defending legal claims;
To enforce our terms and conditions;
To protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and

To allow us to pursue available remedies or limit the damages that we may sustain.

3. Marketing

Where required by local law, we will obtain your prior consent:

In order to send you marketing communications about CPC; and
In order to provide your personal data to affiliated companies within the CPC family of companies for their marketing purposes; and
In order to provide your personal data to other partners for joint marketing efforts.

Please note that you always have the right to withdraw your consent. If you would like to unsubscribe or opt-out from our marketing, please contact us at dataprivacy@colder.com.

Otherwise we may contact you by email, phone, mail, or other means unless you direct us not to do so.

We may use your personal data for our own marketing purposes, including but not limited to notifying you of new services, offers or other information via mail, email, telephone, text message, and other means. We will only do this with your consent where required.

If you have previously consented but no longer want us to use your personal data for marketing purposes or to provide your personal data to CPC’s Affiliates or other partners for their marketing purposes, you may opt-out of such uses by notifying us in accordance with the procedure set forth below under the heading “Rights to Your Personal Data.”

4. Disclosures of Personal Data For Business Purposes

The following chart describes the categories of personal data that we disclosed to third parties for a business purpose:

Categories of Consumers’ Personal Data	Categories of Third Parties With Which We Disclose Personal Data for a Business Purpose
Personal identifiers: name; contact details; IP address; email address; and telephone number.	Service providers that facilitate scheduling and email communications; provide security services and cloud-based data storage, assist with other IT-related functions; provide Site analytics; provide legal and accounting services; host or facilitate teleconferencing or video conferencing services. Professional Service providers including lawyers and financial advisors. Authorized Distributors of CPC.
Commercial information: records of products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.	Service providers that facilitate scheduling and email communications; host or facilitate teleconferencing or video conferencing services Professional Service providers including lawyers and financial advisors.
Internet or other electronic activity information: information we obtain through your interaction with our Site, including time and date of your visit, pages visited, length of visit.	Service providers that facilitate scheduling and email communications; provide security services and cloud-based data storage, assist with other IT-related functions; provide Site analytics.

We may share your personal data with third party service providers (including contractors who provide services to us) to assist with any of the uses of personal data described above. Additionally, your personal data may be provided to marketing automation platforms that we use to assist us in understanding who is visiting our website. For further information see our Cookie Notice.

We may also disclose your personal data to third parties if disclosure is required to comply with applicable laws or regulations; comply with legal process or a court order; to respond to requests from public and government authorities; or if disclosure is necessary to enforce our Terms of Use; to protect your safety or security; to protect our rights, the safety and security of our site and property or that of CPC’s Affiliates or third parties; to allow us to pursue available remedies or limit the damages we may sustain. We may share or transfer your personal data to a third party if Dover enters into, or is involved in, a business transaction such as a merger, acquisition, reorganization, or sale of some or all of its assets.

No Sale of Personal Data: We do not sell your personal data.

We do not intend to collect any sensitive personal data (which is defined under EU law to include, for example, personal data on ethnicity, racial origin and health) through the CPC website.

5. Security and Confidentiality

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security. Additionally, we are not able to guarantee the confidentiality of non-confidential data such as feedback, questions, comments or ideas that you voluntarily provide to us (e.g., via the “Contact” tab or similar features on the Site). We reserve the right to use and disclose such non-confidential information as we deem appropriate in compliance with applicable law.

6. How Long Will We Hold Your Personal Data

We will retain your personal data for as long as:

We have a relationship with you;
We are required by law; or
We need to in order to protect ourselves as a business or protect any other third party.

If you have any questions about our retention policy, please contact us using the details set out above.

7. Transfers of Personal Data

As a global organization, we will transfer your personal data across borders. CPC is based in the US although our Affiliates are located in countries worldwide. This means that if you interact with our UK or EEA Affiliates, your personal data could be transferred to our company in the US. Where we are required to protect a transfer of personal data across borders, we will implement appropriate or suitable safeguards (such as EU Commission approved Standard Contractual Clauses or an intercompany agreement with appropriate contractual protections) to protect that personal data. Please contact us using our details above should you require further information about the contractual protections we use.

8. Links to Other Websites

The CPC website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any personal data which you provide whilst visiting such sites and such sites are not governed by this Notice. You should exercise caution and look at the privacy statement applicable to the web site in question.

Our Site also uses plug-ins from these social media platforms: Facebook, LinkedIn, Twitter and YouTube. You can read more regarding how these social media platforms process your data at the following links:

Facebook: https://en-gb.facebook.com/privacy/explanation
LinkedIn: https://www.linkedin.com/legal/privacy-policy
Twitter: https://twitter.com/en/privacy
YouTube: https://policies.google.com/privacy?hl=en-GB
ClickDimensions: https://clickdimensions.com/about/privacy-policy/
PartSolutions: https://partsolutions.com/terms/privacy-policy/
Siteimprove: https://www.siteimprove.com/privacy/
OneTrust: https://www.onetrust.com/privacy-notice/
Cludo: https://www.cludo.com/privacy-policy
Hotjar: https://www.hotjar.com/legal/policies/privacy/
Youku: https://terms.alicdn.com/legal-agreement/terms/platform_service/20220525165926567/20220525165926567.html
InterShop: https://www.intershop.com/en/privacy-policy

We have a fan page or a company page on Facebook or LinkedIn that you can use or visit. For those pages, we act as a joint controller with the social media platform for the collection of your personal data.

You can read more regarding our joint controllership with the platforms at the following links:

LinkedIn: https://legal.linkedin.com/pages-joint-controller-addendum

Facebook: https://www.facebook.com/legal/controller_addendum

9. Rights to Your Personal Data

Under certain laws, you have the right to seek access to your personal data, seek rectification or erasure of your personal data, restrict our use of your personal data, object to our use or request data portability. Please contact us if you wish to exercise any of these rights. In any event, you can always ask us for more information about the people who will be able to see and access your personal data.

Please use the details above to contact us if you want to exercise any of the rights set out below in relation to your personal data:

the right to access your personal data that we hold about you
the right to rectification of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected;
the right to erasure of your personal data if your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed or if your personal data has been processed unlawfully;
the right to restriction of the processing of your personal data;
the right to data portability;
the right to withdraw any consents for data processing you have provided;
the right to object to the processing where there is no compelling legitimate grounds for the processing on our side which overrides the interests, rights and freedoms of the individual or if your personal data is not used for the establishment, exercise or defense of our legal claims.

Please note that you may not have all these rights depending on which law applies to our use of your personal data. Additionally, there may be certain exemptions available to us that we can rely on in handling your request.

You also have a right to file a complaint with a data protection supervisory authority. If you are in the UK, your supervisory authority is the Information Commissioner's Office – we have included a link to their website here. If you are in the EU and have concerns in relation to CPC processing of your personal data, you can find the relevant contacts details for the regulator here (https://edpb.europa.eu/about-edpb/about-edpb/members_en).

In accordance with applicable laws, you may choose to restrict the collection or use of your personal data by us by emailing us at dataprivacy@colder.com. This includes where you:

Have previously not objected to us using your personal data for our direct marketing purposes but now wish to opt out of receiving future marketing emails from us;
Want to opt out of any new uses of personal data permitted by this Notice caused by changes in our information practices;
Do not want us to share your personal data with Affiliates or other partners for marketing purposes;
Believe that personal data we are holding on you is incorrect or incomplete so that we can consider your concern and, where appropriate, we will promptly correct any personal data found to be incorrect. Or, you may contact us if you wish to review or change your personal data by using the “Contact” tab on our home page; or
Do not want to be contacted by us in the future (unless you initiate the contact).

You may also write to us at the above address (located at the beginning of this Notice) or call us at +1-651-645-0091 or toll free at 1-800-444-2474.

California Privacy Rights

Some states within our licensed markets have laws that give privacy rights to their residents. This section addresses the California Privacy Rights Act of 2020 (CPRA), which provides Californians with certain rights and choices about their Personal Information.

A. Notice at Collection of Personal Information

Californians have the right to know what Personal Information is collected by CPC. Our Notice describes:

The categories of Personal Information and Categories of Sensitive Personal Information Processed by CPC.
Our business purposes for processing the categories of Personal Information and Sensitive Personal Information.
Whether we sell or share the categories of Personal Information we collect.
Our retention practices.

B. Notice of Right to Limit Use of Sensitive Personal Information

If sensitive data is used to create inferences, Californians have the right to limit CPC’s processing of their Sensitive Personal Information to business purposes that are reasonable and necessary to provide requested goods and services and for other reasons allowed under applicable law. We do not collect or use sensitive data to create inferences, please contact us at dataprivacy@colder.com or 1-800-444-2474 with questions.

C. Summary of CPRA Rights

The CPRA provides Californians with the following rights and choices regarding their Personal Information.

Correct
Californians have the right to request the correction of their inaccurate Personal Information and, once we receive a verifiable request, CPC must take reasonable steps to correct the inaccurate data.
Delete

Californians have the right to request the deletion of their Personal Information and, once we receive a verifiable request, CPC must comply unless an exception applies. The CPRA lists several exceptions, including:
- The data is necessary to complete a transaction for that person.
- The data is necessary to fulfill a warranty or support a product recall.
- The data is necessary to provide goods or services requested by that person.
- The data is necessary to perform a contract between CPC and that person.
- The data is reasonably used within the context of the ongoing business relationship between CPC and that person.
- CPC uses the data to identify and repair issues with our Services.
- CPC must retain the data to comply with a legal obligation.
Do Not Sell/Share

If CPC sold or shared Personal Information, Californians have the right to opt-out of CPC’s sale/sharing of their Personal Information.
Freedom from Discrimination

CPC may not discriminate against Californians who exercise their rights under the CPRA.
Limit

Californians have the right to limit CPC’s use or disclosure of their Sensitive Personal Information as defined under California law.
Know

Californians have the right to know what Personal Information is or has been collected by CPC in the 12 months prior to receipt of a request. If a request is made and verified, we must disclose, with respect to the Personal Information collected about the requestor, the following:
- The categories of Personal Information and Sensitive Personal Information we have collected.
- Our sources of Personal Information.
- The categories of Personal Information we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Our purposes for collecting and selling/sharing Personal Information.
- Furthermore, Californians have the right to request access to specific pieces of Personal Information we have collected about them and, once we receive a verifiable request, CPC must provide this data in accordance with California law.

D. Exercising Your Rights and How We Will Respond

To exercise any of the rights above, or to ask a question, contact us at 1-800-444-2474; www.cpcworldwide.com/Contact-Us; or dataprivacy@colder.com.

For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.

If we expect your request is going to take us longer than normal to fulfill, we will let you know.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.

E. Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination

If you exercise any of the rights explained in this Policy, we will continue to treat you fairly. If you exercise your rights under this Notice, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.

F. Verification of Identity – Access or Deletion Requests

We will ask you for identifying information and attempt to match it to information that we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.

G. Authorized Agents

You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.

If you would like to designate an agent to act on your behalf to request or delete Personal Information, you and the agent will need to comply with our verification process: If the agent submits requests to access, know or delete your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

H. California Shine the Light Law

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents that have an established business relationship with a business to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for those parties’ direct marketing purposes in the preceding calendar year. For information and to make a request, contact us at dataprivacy@colder.com or you can call us at 651-645-0091 or toll free at 1-800-444-2474.

Virginia Privacy Rights

If you are a Virginia resident, the Virginia Consumer Data Privacy Act (“VCDPA”) grants you the following rights with respect to the personal information we collect about you:

Right to Know: Virginia residents have the right to confirm whether or not we are processing their personal information and to access such data, including by obtaining a copy of data that they previously provided to us.
Right to Delete: Virginia residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted.
Right to Correct: Virginia residents have the right to ask that we correct inaccuracies in their personal information, taking into account the nature of personal information and purposes of processing such information.

A. Exercising your Rights

To exercise any of the rights above, or to ask a question, contact us at dataprivacy@colder.com or 651-645-0091. All requesters will be required to authenticate themselves before we respond to their request.

B. Verification Process

C. Response Timeline and Additional Information

For requests to know, delete or correct personal information, we will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer to fulfill, we will let you know.

10. Personal Data of Minors

We do not knowingly collect or allow the collection of personal data from persons under the age of 18. If you are the parent or guardian of a person under the age of 18 and believe that the person has provided personal data to us, please contact us at dataprivacy@colder.com.

11. Cookies

When you visit the CPC website, we may use “cookies” and similar technologies to help us recognize and serve you better. Cookies are small files that contain information sent by a web site that is saved on your computer’s hard drive. You may delete cookies from your computer or set your browser to reject cookies. However, doing so may limit some functionalities of our site.

Our Site uses cookies and/or other similar technologies such as device-IDs, pixel tags and web beacons to collect and store information about you.

What are cookies?

Cookies are pieces of information or code that a website transfers to or accesses from your computer or device to store, and sometimes track, information about you.

Cookies let websites remember you and your preferences, manage different features and content, store searches, and personalise content.

How does our Site use cookies?

Our Site uses cookies (alone or combined) to create a unique device ID, and to distinguish you from other users. This helps us to improve your experience and improve our Site. We also use cookies to keep our Site secure and to understand how users navigate around the Site.

Some cookies only last while you use our Site and others are used to remember you when you visit again, lasting longer.

We use strictly necessary cookies if it is in our legitimate interests to do so (balanced with your rights). These are cookies where the storage of (or access to) information is essential rather than reasonably necessary. For instance, we need to use these cookies in order to provide a service to you. Additionally, these cookies can be strictly necessary in order to comply with a legal obligation we are subject to.

We use all other cookies with your consent. You can choose which cookies to consent to through our Privacy Preference Centre which is available to you through the Cookie Banner.

Privacy Preference Centre

You can choose which cookies (apart from those that are strictly necessary) you wish us to place on your device by setting your preferences in the Privacy Preference Centre which is accessible through the Cookie Banner. You can always change your settings and revoke your consent at any time.

Disabling Cookies

You can also choose to disable cookies through browser settings. The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.

If you want to disable cookies on our website, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.

We set out here steps to follow for the most widespread browsers.

Microsoft Internet Explorer

Select the Tools menu > Internet Options
Click on the Privacy tab
Click on Advanced within the Settings section and select the appropriate setting

Google Chrome

Select Settings > Advanced
Under Privacy and Security > Content settings.
Click Cookies and select the relevant options

Safari

Select Preferences > Privacy
Click on Remove all Website Data

Mozilla Firefox

Choose the Tools menu > Options
Click on the Privacy icon
Select the Cookie menu and select the relevant options

Opera 6.0 and further

Choose Files menu > Preferences
Select Privacy

We may also separately prompt you regarding our use of cookies on the Site.

Contact Us

Updating this Cookie Policy

We may update our use of cookies from time to time and consequently we may update this policy. We recommend you check this policy regularly. We will notify you of any significant changes by way of a notice on our website or by contacting you directly where reasonably possible.

Last Updated: July 2023

12. Contact Us

Any inquiries about this Notice, updates to your personal data, requests (including those regarding the exercise of your rights), and questions can be directed to us via e-mail at dataprivacy@colder.com or you can call us at 651-645-0091, 1-800-444-2474. If you are in the EEA or the UK please contact us at +49-6105-9743-003, dataprivacy.eu@colder.com.

13. Updates to This Notice

We may update this Notice by posting a new version on our website. If we update this Notice in a way that significantly changes how we use your personal data, we will bring these changes to your attention where reasonably possible. Otherwise, we recommend that you periodically review this Notice to be aware of any other revisions.