1. ABOUT THIS POLICY
Growl Products Inc. and its affiliate Growl Products US Inc. ("Growl", "we", "us", or "our") respect your privacy. This Privacy Policy explains what personal information we collect through www.growlproducts.com and any related website or web page that links to this Policy (the "Site"), why we collect it, who we share it with, how long we keep it, how we protect it, and the rights and choices available to you.
This Policy also applies to personal information we collect when you contact us by email or telephone, when you meet us at a trade show, and when we correspond with dealers, distributors, suppliers, and prospective business partners, except where a separate notice is provided.
We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the British Columbia Personal Information Protection Act (PIPA), Canada's Anti Spam Legislation (CASL), the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, the "CCPA"), and other United States state privacy laws that apply to us.
This Policy does not apply to information collected on a third party website, even if you reach that website through a link on the Site. See Section 13.
2. PERSONAL INFORMATION WE COLLECT
2.1 Information you give us directly
We collect personal information you choose to provide, including when you submit a contact form, subscribe to a newsletter, download a catalogue or specification sheet, request dealer information, or email or call us. This typically includes:
- Identifiers and contact details: name, business email address, telephone number, mailing or shipping address.
- Professional and employment information: company or organization name, job title, industry, dealer or distributor status, territory.
- Commercial and enquiry information: the products or product lines you ask about, quantities or applications you describe, purchase interests, and the content of the message you send us.
- Marketing preferences: whether you have consented to receive commercial electronic messages, and the record of that consent, including the date, time, and method by which it was given.
- Any other information you volunteer in free text fields. Please do not include sensitive personal information in a message to us. We do not need it and we do not ask for it.
2.2 Information collected automatically
When you visit the Site, we and our service providers may automatically collect:
- Internet and network activity information: IP address, browser type and version, operating system, device type, screen resolution, language setting, referring URL, exit pages, pages viewed, files downloaded, search terms used on the Site, dates and times of access, clickstream data, and session duration.
- Approximate location: a general geographic area, such as city, region, and country, inferred from your IP address. We do not collect precise geolocation from the Site.
- Cookie and similar identifiers: see Section 6.
2.3 Information from other sources
We may receive personal information from our dealers and distributors, from trade show organizers and industry associations where you have provided your details, from publicly available business directories and company websites, from social media platforms where you interact with our pages, and from our analytics and marketing service providers.
2.4 Information we do not collect
We do not knowingly collect personal information from children. See Section 14.
We do not collect payment card information through the Site. The Site does not process transactions.
We do not seek to collect special categories of personal information, such as health information, biometric data, racial or ethnic origin, religious beliefs, or precise geolocation. If you send us such information in a free text message, we will handle it in accordance with this Policy and delete it where it serves no purpose.
2.5 CCPA categories
For the purposes of the CCPA, in the preceding twelve months we have collected the following statutory categories of personal information: identifiers; personal information described in California Civil Code section 1798.80; commercial information; internet or other electronic network activity information; geolocation data (approximate, non precise); and professional or employment related information. We do not collect biometric information, sensitive personal information, education information as defined by that statute, or draw inferences to create a consumer profile reflecting personal characteristics.
3. WHY WE COLLECT AND USE PERSONAL INFORMATION
We use personal information only for the purposes identified below or for a purpose you consent to at the time of collection. We use it to:
- respond to your enquiry, quotation request, sample request, or message, and to follow up on it;
- connect you with an authorized Growl dealer or distributor in your territory;
- provide product information, specification sheets, safety data, certifications, catalogues, and other requested materials;
- establish, manage, and support our relationship with dealers, distributors, suppliers, and prospective business partners;
- send commercial electronic messages, newsletters, product announcements, and promotional material where you have given the consent required by CASL, CAN SPAM, and other applicable law, and to manage that consent;
- operate, maintain, secure, and improve the Site, diagnose technical problems, and analyze how the Site is used so that we can make it more useful;
- measure and improve the performance of our marketing, including understanding which content and campaigns are effective;
- detect, investigate, prevent, and respond to fraud, security incidents, misuse of the Site, and violations of our Terms and Conditions of Use;
- establish, exercise, or defend legal claims, obtain legal or professional advice, and conduct or evaluate a corporate transaction; and
- comply with our legal, regulatory, tax, product safety, and record keeping obligations.
We will not use personal information for a new purpose that is materially different from those above without first obtaining your consent, unless the law permits or requires the new use.
4. LEGAL BASIS AND CONSENT
Under Canadian privacy law, we collect, use, and disclose personal information with your knowledge and consent, except where the law permits or requires otherwise.
Express consent. We rely on your express consent for marketing communications. You give express consent when you tick a subscription box, submit a signup form, or otherwise clearly agree to receive commercial electronic messages from us.
Implied consent. Where you provide your business contact information for the purpose of an enquiry, we treat your consent as implied for the purpose of responding to that enquiry and for the purposes identified in Section 3 that are reasonably related to it. CASL also permits us to send commercial electronic messages on the basis of an existing business relationship or a conspicuously published business email address, in the circumstances that statute allows.
Business contact information. Canadian privacy legislation treats business contact information collected and used solely for the purpose of communicating with an individual in relation to their employment, business, or profession differently from other personal information. Where that exemption applies, we rely on it.
Withdrawing consent. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may limit our ability to provide information or services to you. To withdraw consent, use the unsubscribe link in any commercial message or contact our Privacy Officer at the address in Section 17. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
5. HOW WE DISCLOSE PERSONAL INFORMATION
We do not sell personal information. See Section 8 for what that means under the CCPA.
We disclose personal information only as described below.
Service providers and processors. We use third parties to perform services on our behalf, including website hosting and content delivery, email and marketing platforms, customer relationship management, analytics, form processing, cloud storage and productivity software, IT support and security, and professional advisers. These providers are given only the personal information they need to perform their function, are bound by contract to protect it and to use it only on our instructions, and are prohibited from using it for their own purposes.
Affiliates. We share personal information between Growl Products Inc. and Growl Products US Inc. for the purposes described in this Policy, including routing an enquiry to the entity that serves your region.
Authorized dealers and distributors. If you ask to be connected with a dealer, or if your enquiry is best handled by the dealer serving your territory, we will share your enquiry and contact details with that dealer so they can respond. That dealer is an independent business and its own privacy practices apply to what it does with your information after that point.
Legal and regulatory. We disclose personal information where required or permitted by law, including in response to a subpoena, court order, warrant, audit, or lawful request by a government or regulatory authority in Canada, the United States, or another jurisdiction; to establish, exercise, or defend legal claims; to enforce our Terms and Conditions of Use; and to protect the rights, property, or safety of Growl, our customers, or the public.
Corporate transactions. If Growl is involved in a merger, acquisition, financing, reorganization, or sale of all or part of its assets, personal information may be disclosed to the parties involved and their advisers, subject to appropriate confidentiality protections, and may be transferred as part of the transaction.
With your consent. We disclose personal information for any other purpose you consent to.
6. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small text file placed on your device by a website. We and our service providers use cookies, pixels, tags, and similar technologies on the Site for the following purposes:
- Strictly necessary. Required to operate the Site, route traffic, maintain session state, and protect against security threats. These cannot be switched off through our cookie controls.
- Preference. Remember choices you make, such as language, region, or whether you have dismissed a banner.
- Analytics and performance. Help us understand how visitors find and use the Site, which pages and products draw interest, and where the Site can be improved. We use third party analytics providers for this purpose.
- Marketing and advertising. Where used, these measure the performance of our campaigns and may allow advertising platforms to show you Growl content on other websites. [CONFIRM AND EDIT: list the specific platforms in use, for example Google Ads, LinkedIn Insight Tag, Meta Pixel, or delete this bullet if the Site runs no advertising or retargeting technology.]
Managing cookies. Most browsers let you refuse or delete cookies through their settings. Blocking strictly necessary cookies may prevent parts of the Site from working. Where we use a cookie banner or preference centre, you can change your choices there at any time using the link in the Site footer.
Global Privacy Control. We treat an enabled Global Privacy Control signal, or an equivalent browser or extension based opt out preference signal, as a valid request to opt out of the sale or sharing of personal information for the browser and device on which it is received.
Do Not Track. There is no common industry standard for responding to browser Do Not Track signals, and the Site does not currently respond to them. We do respond to Global Privacy Control signals as described above.
Analytics opt out. You can opt out of Google Analytics across all websites by installing the browser add on available from Google at https://tools.google.com/dlpage/gaoptout.
7. WHERE YOUR INFORMATION IS STORED AND PROCESSED
Growl operates in Canada and the United States. Personal information we collect may be stored, accessed, and processed in Canada, in the United States, and in other countries where our service providers maintain facilities.
This means your personal information may be subject to the laws of a jurisdiction other than your own, and may be accessible to the courts, law enforcement agencies, national security authorities, and regulatory bodies of that jurisdiction under the laws in force there, including lawful access requests made without notice to you.
When we transfer personal information outside your jurisdiction, we use contractual and other measures intended to provide a comparable level of protection to that required under applicable Canadian law, and we remain accountable for personal information transferred to a service provider for processing.
To ask where a particular category of personal information is stored, contact our Privacy Officer at the address in Section 17.
8. NO SALE OR SHARING OF PERSONAL INFORMATION
We do not sell personal information, and we have not sold personal information in the preceding twelve months, as "sell" is defined in the CCPA and comparable United States state privacy laws. We do not sell the personal information of minors under 16 years of age.
[CONFIRM: If the Site uses advertising, retargeting, or cross context behavioural advertising technology such as a Meta Pixel, Google Ads remarketing tag, or LinkedIn Insight Tag, then under the CCPA the Site may be "sharing" personal information for cross context behavioural advertising even though no money changes hands. If any such technology is in use, replace this paragraph with a disclosure of that sharing, add a "Do Not Sell or Share My Personal Information" link to the Site footer, and describe the categories shared and the categories of recipient. If no such technology is in use, delete this bracketed paragraph and leave the statement above.]
We do not use or disclose sensitive personal information for purposes that require us to offer a right to limit its use under the CCPA.
9. HOW LONG WE KEEP PERSONAL INFORMATION
We keep personal information only as long as necessary to fulfil the purposes for which it was collected, or as required by law.
- Enquiries and correspondence: retained for the duration of the enquiry and for a reasonable period afterwards to maintain a record of the relationship, generally not more than seven years.
- Marketing subscriptions and consent records: retained while your subscription is active and for a period afterwards sufficient to demonstrate compliance with CASL and CAN SPAM, generally three years after consent is withdrawn.
- Dealer, distributor, and supplier records: retained for the term of the relationship and for the period required by applicable tax, corporate, and limitation legislation.
- Website analytics data: retained in accordance with the retention settings of the analytics platform, generally not more than twenty six months.
- Records subject to a legal hold: retained until the hold is lifted.
If we used personal information to make a decision that directly affects you, we retain it for at least one year after that decision, as required by Canadian privacy legislation, so that you have an opportunity to access it.
When personal information is no longer required, we destroy, erase, or anonymize it using measures appropriate to its sensitivity.
10. HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the personal information we hold. These include encryption of data in transit using TLS, access controls that limit access to personnel who need it to do their job, authentication requirements on business systems, secured premises, agreements with service providers that impose confidentiality and security obligations, and internal policies governing the handling and disposal of personal information.
No method of transmission over the internet and no method of electronic storage is completely secure. We cannot guarantee absolute security, and any transmission of personal information to us is at your own risk. If we become aware of a breach of security safeguards involving personal information that creates a real risk of significant harm, we will notify affected individuals and the applicable regulators as required by law.
11. YOUR RIGHTS AND CHOICES
11.1 Rights available to everyone
Access. You may request access to the personal information we hold about you, along with an account of how it has been used and to whom it has been disclosed.
Correction. You may request that we correct personal information that is inaccurate or incomplete. Where we agree, we will correct it and, where appropriate, notify third parties to whom the information has been disclosed.
Withdraw consent. You may withdraw consent to the collection, use, or disclosure of your personal information, subject to legal and contractual restrictions and reasonable notice.
Unsubscribe. You may opt out of marketing communications at any time using the unsubscribe link in any message or by contacting us.
Complain. You may complain to us about our handling of your personal information, and we will investigate.
11.2 Additional rights for residents of California and other United States states with comprehensive privacy laws
Depending on your state of residence, you may have the right to:
- know the categories and specific pieces of personal information we have collected about you, the categories of source, the business or commercial purpose for collecting it, and the categories of third party to whom it is disclosed;
- delete personal information we have collected from you, subject to statutory exceptions;
- correct inaccurate personal information;
- obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format;
- opt out of the sale or sharing of personal information and of targeted advertising, and to have an opt out preference signal honoured;
- limit the use and disclosure of sensitive personal information;
- opt out of profiling in furtherance of decisions producing legal or similarly significant effects, which we do not carry out; and
- not be discriminated against for exercising any of these rights. We will not deny you goods or services, charge you a different price, or provide a different level of quality because you exercised a privacy right.
Appeals. If we decline your request and you reside in a state that provides an appeal right, including Virginia, Colorado, Connecticut, Montana, Oregon, Texas, and others, you may appeal by replying to our decision within a reasonable period and marking your message "Privacy Appeal". We will respond in writing within the period your state's law requires. If your appeal is denied, you may contact your state Attorney General.
11.3 How to exercise your rights
Send your request to our Privacy Officer using the contact details in Section 17. Describe the right you are exercising and provide enough information for us to locate your records.
Verification. To protect your privacy, we will take reasonable steps to verify your identity before acting on a request. We may ask you to confirm information we already hold. We will not use information you provide for verification for any other purpose.
Authorized agents. An authorized agent may submit a request on your behalf with written proof of authority. We may still contact you to confirm the authorization and to verify your identity.
Response times. We respond to access and correction requests under Canadian privacy law within 30 days, and may extend that period where the law permits, in which case we will tell you. We respond to CCPA requests within 45 days, with a further 45 day extension where reasonably necessary, and confirm receipt within 10 business days. There is no charge for a request unless it is manifestly unfounded or excessive, in which case we will give you an estimate in advance and you may withdraw the request.
Limits. Access and other rights are not absolute. We may decline a request where the law requires or permits us to do so, for example where disclosure would reveal personal information about another individual, would reveal confidential commercial information, is subject to solicitor client privilege, or relates to an ongoing investigation. Where we decline, we will explain why and tell you how to challenge the decision.
11.4 Complaints to a regulator
If you are not satisfied with our response, you may contact:
- Office of the Privacy Commissioner of Canada 30 Victoria Street, Gatineau, QC K1A 1H3 1-800-282-1376 www.priv.gc.ca
- Office of the Information and Privacy Commissioner for British Columbia PO Box 9038 Stn Prov Govt, Victoria, BC V8W 9A4 250-387-5629 www.oipc.bc.ca
- California residents may contact the California Privacy Protection Agency at cppa.ca.gov or the California Attorney General at oag.ca.gov. Residents of other states may contact their state Attorney General.
12. CALIFORNIA SHINE THE LIGHT
California Civil Code section 1798.83 permits California residents to request information about the disclosure of personal information to third parties for those parties' own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes. To make a request under this section, contact our Privacy Officer.
13. THIRD PARTY WEBSITES AND SOCIAL MEDIA
The Site links to third party websites, including online catalogues, dealer websites, and our social media pages. This Policy does not apply to those properties. We do not control and are not responsible for the privacy practices of any third party. Review the privacy policy of any website you visit through a link on the Site.
If you interact with Growl on a social media platform, that platform's privacy policy governs its collection and use of your information. We may see and use information you make publicly available on that platform, and we may receive aggregated analytics from the platform about our pages and content.
14. CHILDREN
The Site is directed to a business and industrial audience and is not intended for children. We do not knowingly collect personal information from anyone under the age of 16, and we do not knowingly sell or share the personal information of anyone under 16. If you believe a child has provided us with personal information, contact our Privacy Officer and we will delete it.
15. AUTOMATED DECISION MAKING
We do not use personal information collected through the Site to make automated decisions that produce legal effects concerning you or that similarly significantly affect you, and we do not engage in profiling for that purpose.
16. CHANGES TO THIS POLICY
We may update this Policy from time to time to reflect changes in our practices, our technology, or the law. The revised Policy takes effect when posted, and the "Last Updated" date above will change. Where a change is material, we will provide additional notice, which may include a notice on the Site or an email to subscribers, and where the law requires it we will obtain your consent. Review this Policy periodically.
17. CONTACT OUR PRIVACY OFFICER
We have designated a Privacy Officer accountable for our compliance with this Policy and with applicable privacy legislation. Direct questions, access requests, corrections, withdrawals of consent, and complaints to:
Privacy Officer Growl Products Inc. Unit 580, 8621 201 Street Langley, BC V2Y 0G9 Canada
Email: [INSERT PRIVACY EMAIL, for example privacy@growlproducts.com] Phone: 888-583-0095
United States enquiries may also be directed to:
Privacy Officer Growl Products US Inc. 1 Industry Drive Bedford, OH 44146 USA
We will acknowledge your enquiry and respond within the time frames set out in Section 11.3.