APEC Water Privacy and Security Policy

APEC Water Systems Privacy Notice

Effective Date: October 2nd, 2023

 

Welcome to APEC Water Systems’ (“APEC,” “we,” “us,” or “our”) website. This APEC Water Privacy Notice (“Privacy Notice”) applies to your use of our websites, including www.freedrinkingwater.com, our mobile apps, and to other information we collect online (together, our “Services”). When we refer to “you,” “your,” or “user,” we refer to the person using or accessing the Services.

If you are a California resident, please see our California Privacy Notice provided pursuant to the California Consumer Protection Act, as amended (“CCPA”), below, for more information about how we may collect, use, and disclose your personal information.

This Privacy Notice should be read in conjunction with APEC’s Terms of Use, and any other policy, agreement, or terms which may affect your relationship with APEC.  Please read this Privacy Notice and Terms of Use carefully before using our Services.  By using our Services or otherwise providing personal information to us, you agree to our Terms of Use and consent to our data collection, use, and disclosure practices, and other activities as described in this Privacy Notice.  If you do not agree, please discontinue use of the Services.

CONTENTS

• PERSONAL INFORMATION WE COLLECT & WHY WE COLLECT IT
• HOW WE COLLECT YOUR PERSONAL INFORMATION
• HOW WE DISCLOSE PERSONAL INFORMATION
• SOCIAL FEATURES ON OUR SERVICE
• ANALYTICS
• YOUR CHOICES ABOUT TRACKING & COMMUNICATIONS
• SECURITY & PASSWORDS
• AGE RESTRICTIONS
• DATA RETENTION
• CALIFORNIA PRIVACY NOTICE
• INTERNATIONAL TRANSFERS
• CHANGES TO THE PRIVACY NOTICE
• HOW TO CONTACT US

PERSONAL INFORMATION WE COLLECT & WHY WE COLLECT IT 

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

The chart below summarizes the types of Personal Information we collect and why we collect it. APEC may use your Personal Information for any purposes not inconsistent with APEC’s statements under this Privacy Notice, or purposes otherwise made by us in writing at the point of collection, and purposes not prohibited by applicable law, including the purposes listed below.

CATEGORY OF PERSONAL INFORMATION	EXAMPLES	PURPOSE(S) FOR COLLECTION
Contact Information and Identifiers	•  Real name, account name, username, unique personal identifier, online identifier, IP address, email address, or other similar identifiers	•  To allow you to participate in the features we offer •  To maintain your accounts with us •  To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback •  To send you marketing materials and advertisements •  To recognize you when you use our Services •  To show you relevant ads while you browse the internet or use social media •  To send you relevant coupons, discounts, or promotions •  Auditing, research and analysis, to maintain and improve our Services, and for any other internal business purposes •  To detect and prevent fraud against you and/or us •  For potential litigation and other legal or regulatory requirements
Commercial Information	•  Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	•  To allow you to participate in the features we offer  •  To provide you with appropriate products and recommendations •  To help you find relevant products more quickly •  To tailor our communications to you •  To provide customer service and support •  To send you relevant coupons, discounts, or promotions •  To improve our Services, and our products, marketing and advertising •  Auditing, research and analysis, to maintain and improve our Services, and for any other internal business purposes •  To detect and prevent fraud against you and/or us
Demographic Information	•  Age and birth date	•  To allow you to participate in the features we offer •  To send you relevant marketing materials and advertisements •  To tailor our communications to you •  To improve our Services, and our products, marketing and advertising •  Auditing, research and analysis, to maintain and improve our Services, and for any other internal business purposes •  To detect and prevent fraud against you and/or us •  For potential litigation and other legal and regulatory requirements
Internet or Other Electronic Network Activity Information	•  Internet or other similar activity, browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information	•  To allow you to participate in the features we offer •  To provide you with appropriate products and recommendations •  To help you find relevant products more quickly •  To tailor our communications to you •  To provide customer service and support •  To send you relevant coupons, discounts, or promotions •  To improve our Services and our products, marketing, and advertising •  Auditing, research and analysis, to maintain and improve our Services, and for any other internal business purposes •  To detect and prevent fraud against you and/or us
Geolocation Data	•  Your physical location based on information you provide directly or inferred from your IP address	•  To allow you to participate in the features we offer •  To send you relevant coupons, discounts, or promotions •  Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
Audiovisual Information	•  Audio recordings of customer care calls, video, or similar information	•  To provide you with customer service •  To improve our products and Services •  For litigation and other legal and regulatory requirements
Communications with Us	•  The contents of your communications with us via phone, email, text message, chat, or other means (such as survey responses, product reviews, and comments on our blog and social media pages)	•  To communicate with you about our products and Services, your orders, and to provide customer service and support •  To improve our websites, apps, products, and marketing •  To allow you to participate in our promotions, sweepstakes, contests, and loyalty programs •  To detect and prevent fraud against you and/or us •  For litigation and other legal and regulatory requirements
Inferences About You from Any Other Category of Information We Collect	•  Information reflecting your preferences, characteristics, trends, or attitudes	•  To provide you with appropriate products and recommendations •  To improve our Services, and our products, marketing and advertising •  To provide you with a better website or app experience •  Auditing, research and analysis, to maintain and improve our Services, and for any other internal business purposes •  To detect and prevent fraud against you and/or us

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect your Personal Information through various means, including when you directly provide it to us and automatically through your use of our Services. We may also collect Personal Information about you from our vendors and from other parties. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use features of our Services.

Information that You Provide

We collect Personal Information about you directly when you:

• Register or maintain an account with us
• Enter search terms or provide other information through our Services
• Subscribe to receive our notifications
• Exchange communications with us by mail, email, phone, etc.
• Post comments to our online communities
• Obtain customer service or technical support
• Participate in promotional activities
• Post reviews or other information about our products or Services
• Connect with us via social media

Information Collected Automatically

APEC and/or our vendors may also automatically collect certain information about you when you access or use our Services (“Usage Information”). Usage Information may include your IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computers or mobile devices), the domain name of the website that allowed you to navigate to our Services, search engines used, the length of time spent on our Services, the pages you looked at on our Services, the address (or “URL”) of the websites you visited before and after visiting our Services, the frequency of your visits to our Services, and certain other available information. The methods we use to collect Usage Information include:

• Log Files. Log information is data about your use of our Services, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which may be collected and stored in log files.
• Cookies. We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our website, including information about your browsing behavior. Our website also supports cookies placed by our vendors, affiliates, and advertising partners.
  
  Cookies are small files that a website transfers to your device through a web browser that enable the site’s or a vendor’s systems to recognize your device and to capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our website use cookies and other tracking technologies as follows:
  
  
  • Where necessary to run our Services, for example by allowing you to log in.
  • To optimize the functionality of our Services, including by personalizing content for you, and remembering your preferences (e.g., your choice of language or region).
  • For analytics purposes—for example, to help us understand how our Services are used, to see what products most interest you, and determine how best to market our products to you. More information on website analytics is provided below.
  • For purposes of ad targeting and marketing. These cookies collect information about your browsing behavior on our website in order to show you interest-based advertising when you visit other websites or use social media.
  • To determine if you open or act upon our email messages. Information on unsubscribing from our commercial email communications is provided below.
  • To obtain information about your interactions with our online advertisements, such as whether you clicked on an ad and the Services where you may have seen the ad.
• Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use both session cookies and persistent cookies on our website.
• Web Beacons (“Tracking Pixels”). Web beacons are small graphic images, also known as “internet tags,” “clear GIFs,” or “pixel tags”) embedded in web pages and email messages. Web beacons may be used, without limitation, to count the number of visitors to our Services, to place cookies, to monitor how users navigate our Services, and to count content and advertising views.
• Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with our Services. It is temporarily downloaded onto your computer and is active only while you are connected to our Services and deleted or deactivated thereafter.
• Location-Identifying Technologies. Geo-filtering and other location-aware technologies may locate you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting/providing content based on your location. Content on our Services may be personalized based on various information we may have about you to try to provide you with more location-relevant content.
• Device and Activity Monitoring. Technologies that monitor, and may record, certain of your interactions with our Services, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving our Services and customizing or optimizing your experience on our Services.
• Session Replay. In certain instances, we may contract with service providers to help us analyze activity on our websites, our chat functionality, and mobile apps as applicable, through session replay technologies to help us understand and analyze how visitors use our Services, and to improve the Services. These technologies may collect the following types of information, among others: IP address; screen size; device type (unique device identifiers); browser information; geographic location; and preferred language.

 

Information We Collect from Other Sources

APEC may also obtain information about you from other sources, including our vendors. We also may obtain your Personal Information from our parent, subsidiary, and sister companies. In some circumstances, we obtain Personal Information about you from other parties, including business partners, resellers, and data brokers, some of which may sell the information to us. To understand your rights and choices regarding Personal Information collected by other companies, please consult the privacy policies of the businesses that you interact with.  We are not responsible for the privacy policies or privacy practices of other parties.

HOW WE DISCLOSE PERSONAL INFORMATION

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

• Within our group of companies including with our affiliates, subsidiaries, locations, brands, etc.
• With our agents, vendors, consultants, and other business providers in order for them to provide their services to us. For example, we may disclose your Personal Information to provide customer service, operate and improve our business and our Services, improve our products and customer service, help run our promotions (including coupons and rewards programs), process payments, perform auditing and quality control, communicate with you, and otherwise operate our business.
• With other parties for co-marketing purposes, to improve our products and Services, or to provide you with other products and Services that may interest you.
• With our advertising partners for the purposes of ad targeting, remarketing, and customized advertising content.
• As necessary, for the following purposes: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our Terms and Conditions; (d) to protect our operations and protect our rights, privacy, safety, or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
• With our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, exercising or defending against legal claims, etc.
• With other businesses in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

SOCIAL FEATURES ON OUR SERVICE

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

ANALYTICS

Our website uses analytics technology provided by our vendors to understand how users interact with the site, improve our web experience, and better market our products. Analytics services in use on our website include Yahoo! Analytics. These analytics services use cookies and other Tracking Technologies to collect information about how you use the Service. Personal Information collected by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these providers on servers in the U.S. (or elsewhere). See below for more information on your choices regarding analytics services.

YOUR CHOICES ABOUT TRACKING & COMMUNICATIONS

Cookies and Tracking Technologies

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

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. We do, however, respond to the Global Privacy Control (“GPC”) signal for California residents wishing to opt-out of the “sale” of their Personal Information. 

Analytics and Advertising Technologies

You may choose not to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or the Network Advertising Initiative (“NAI”). To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit http://www.‌aboutads.info/choices/. To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that opting out only means that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).

We also use advertising services provided by Google Ad Services, such as Google Dynamic Remarketing. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content. For more information on how Google uses data collected through our services, visit http://www.‌google.‌com/‌policies/privacy/partners. 

Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s "Limit Ad Tracking" or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID.

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

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

Email Communications

You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending a request to unsubscribe to  support213@freedrinkingwater.com. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.

SECURITY & PASSWORDS

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

AGE RESTRICTIONS

Our Services are intended for adults.  If you are under twenty-one (21) years of age, you are not permitted to use our Services and should not send any Personal Information to us. APEC does not knowingly collect Personal Information as defined by the Children’s Online Privacy Protection Act (“COPPA”). If we learn that we collected Personal Information in a manner not permitted by COPPA, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with Personal Information, please contact us at support213@freedrinkingwater.com. 

DATA RETENTION

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

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (“California Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”), and supplements our Privacy Notice, above. In the event of a conflict between any other APEC policy, statement, or notice and this California Notice, this California Notice will prevail as to California consumers and their rights under and as defined by the CCPA.

This California Notice does not apply to job applicants or current and former California employees/contractors, or their designated beneficiaries, as applicable. If you are a California employee or current or former California employee/contractor, a separate California privacy notice will be provided to you in the course of your employment.  If you are a California job applicant, please review our California applicant privacy notice. If you are a California resident and you believe you interacted with us in a different capacity, or if you have any questions, please contact us as provided below. 

A.      Sales and Sharing of Personal Information

Although we do not sell Personal Information in exchange for money, some of the ways in which we disclose Personal Information for advertising may be considered “sales” or “sharing” under California law.  Listed below are the categories of Personal Information we disclose for purposes of cross-context behavioral advertising or otherwise “sell,” or “share” as defined under California law. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.

 

Category of Personal Information:

• Identifiers
• Personal Information described in Cal. Civ. Code § 1798.80(e)
• Internet or other electronic network activity information
• Geolocation Data
   

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

• Advertising companieS
• Analytics companies
• Social networks
   

Purposes for Selling/Sharing:

• For marketing, advertising, certain types of analytics or similar purposes
• To show you relevant ads while you browse to internet or use social media
   

B.      Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To submit a request, email us at support213@freedrinkingwater.com or call us toll-free at 1-800-880-4808.  Please note that if you submit a request to know, request to delete or request to correct, you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. 

 

1. Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
   1. The categories of Personal Information we have collected about you, including:
      1. The categories of sources from which the Personal Information was collected;
      2. Our business or commercial purposes for collecting, using, selling, sharing, or disclosing Personal Information;
      3. The categories of recipients to which we disclose Personal Information;
      4. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
      5. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
      6. The specific pieces of Personal Information we have collected about you.
2. Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. 
3. Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information. 
4. Right to Opt-Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please click here. If you choose to use the Global Privacy Control (“GPC”) browser signal, you will be opted out of cookie-based sales or sharing of Personal Information, and will need to turn it on for each browser you use. 
5. Right to Limit Use and Disclosure of Sensitive Personal Information. We do not collect, use, or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.  
6. Rights Related to the Use of Automated Decision-making Technology.  APEC will accommodate applicable rights under the CCPA related to automated decision-making technology.
7. Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
8. California “Shine the Light.” We do not share personal information with third parties or affiliates for those other parties’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us as provided below.

 

INTERNATIONAL TRANSFERS

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

 

CHANGES TO PRIVACY NOTICE

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

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

 

HOW TO CONTACT US

If you have any questions or comments about this Privacy Notice or the ways in which we use information subject to this statement, please do not hesitate to contact us by emailing support213@freedrinkingwater.com.