Privacy Policy

Privacy Policy

Issue date March 2024

Privacy Statement EU, Belgium

MARCH 2024

This statement sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information (e.g., name or address) changes during your relationship with us so that we can update our records.

This privacy statement explains:

• Who we are;

• Your rights;

• What personal information do we collect?

• How we use your personal information;

• With whom we share your information and why;

• How we secure your information;

• How long we keep your information; and

• HHow can you contact us?

In this document, “We”, “Us” and “Our” refer to SIP-WELL S.A., located at Technologielaan 3, 1840 Londerzeel, Belgium with company number 0450.274.592.

1. Who we are

Under data protection laws, we are the Data Controller and a proud member of the Culligan International Group (“Culligan”). Culligan is the global leader in delivering cleaner, softer water through innovative, sustainable solutions and unparalleled service across all industries. With more than 13,000 team members and 1,000 dealers in 90 countries, Culligan's more than 35 brands serve more than 50 million customers each year and share the mission of giving consumers better water wherever they need it - at home, at work or on the go. This Privacy Notice covers all entities within the Culligan Group. However, these companies may also have their own Privacy Notices which may supplement this document. If you are resident in the EU (or a country that has adopted a local law to implement or adopt the GDPR) (“EU Residents”), this includes the European General Data Protection Regulation (“GDPR”) or the applicable local law that implements or adopts the GDPR. We have also drafted an intercompany agreement that contains the standard contractual provisions approved by the European Commission to ensure that all transfers of Personal Data to a Culligan entity are protected at the same level as required under European data protection laws.

2. Your legal rights

You have the right to ask us:

• whether we process your personal data and for what purpose (the right to be informed) - this is done through “fair processing information” such as this Privacy Notice; - for a copy of the personal data we hold about you (right to access); - to update or correct your personal information (the right to rectification); - to delete your information (the right to erasure); and - to restrict the processing of your personal information where necessary (the right to limit processing).

In certain circumstances, you also have the right to:

• object to the processing of your personal data (the right to object); - object to automated decision-making and profiling (the right not to be subject to automated decision-making, including profiling); and - request that information about you be provided to a third party in a commonly used, machine-readable form (the right to data portability).

Exercising your rights

For information about your individual rights, including how to correct, limit, delete, change your personal information or if you would like to request a copy of the personal information we hold about you, please contact us here.

Allowances

You do not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. In such circumstances, we may also refuse to comply with the request.

What we may need from you

We may need to ask you for specific information to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to individuals who have no right to receive it. If you are not satisfied with our response or would like more information about your data protection rights, please visit the website of your local data protection authority.

• Consult in Belgium the data protection authority website.

• In the EU, you can contact your local data protection authority here.

3. What personal information we collect

“Personal data” means any information about an individual from which that individual can be directly or indirectly identified. We collect personal information about you that you provide when you apply for a job. This information includes personal information such as your full name, email address and phone number, job title, department, preferences and our communications with you.

Information you provide

We collect personal information about you that you provide when you:

• fill out a contact form on our website;

• contact us about products and/or services;

• subscribe to one of our services;

• Register for a free trial;

• log in to our portal and/or any of our apps;

• respond to a survey;

• request to download guides or other resources on our website;

• attend product events;

• engage with us through our social media channels;

- engage with us through our social media channels.

• opt-in (consent) to receive marketing communications from us; and/or

• apply for a job;

This information includes personal information, such as your full name, e-mail address and phone number, position, department, preferences and our communications with you.

Information we collect about you

The type of personal information we collect depends on the purpose for which the information is collected and may include the following:

• Information about you to identify you and manage your relationship with Culligan (e.g., name, address, email address(es), zip code, phone number(s), title, gender);

• Information about your account with us (e.g., account number, customer ID or number of previous engagements with us, personal preferences, order history, etc;)

• Copies of documentation (e.g., statements, letters, invoices, correspondence);

• Economic & Financial Information (e.g., payment card numbers, bank information, payment history, we also collect some data on behalf of financial institutions regarding the purchase of devices financed by a loan (e.g., pay stubs, address cards, etc.));

• Audio & Visual information when we record interactions with you, or when you visit one of our buildings (e.g., call recordings or Closed Circuit Television “CCTV”);

• Marketing/communication data (e.g., information related to marketing and external communications such as marketing campaigns, opt-in information and preferences); where we have used consent as our legal basis to contact you, this can be revoked at any time;

• Information about your lifestyle (e.g., the amount of water you consume, mineral/vitamin supplements, Information needed to choose the right equipment for your home, such as the number of people living in the particular house, your consumption of tap water, your electricity consumption);

• Information about your website visit, Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plugin types and versions, operating system and platform; including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time) products you viewed or searched for; page response times, download errors, duration of visits to particular pages, information about page interaction (such as scrolling, clicks and mouse-overs) and methods used to exit the page and phone numbers used to call our customer service department;

• Employment and education information (e.g., employer information, relevant professional qualifications, etc.).

We may also collect information about you from other sources, such as:

• other companies within the Culligan Group;

• external third parties (e.g., credit reporting agencies to verify your identity and financial standing, event coordinators when we are present at a booth); and

• from cookies. (Cookies are small text files placed on your computer by websites you visit. They are widely used to make websites work or work more efficiently and to provide information to website owners).

4. How we use your personal information

We will only use your personal information when permitted by law and for the purposes described in this Statement. These are:

• When you consent

• When necessary to perform a contract we have entered into or will enter into with you

• When necessary to comply with a legal or regulatory obligation

• For our legitimate interests or those of a third party, provided that your interests and fundamental rights and freedoms do not outweigh those interests.

We may use your personal information to provide and administer the services you have requested and/or to respond to your inquiries. If you do not provide us with certain information, we may not be able to process your order. We may also use your personal data to comply with our legal obligations, to handle any complaints you may have and to enforce our terms and conditions. We may use your personal data for our legitimate business interests, including security purposes, improvements to our Website, enhancements to our solutions and services, and for general marketing purposes and internal monitoring and reporting. However, we will not do so when our interests outweigh your interests, rights and freedoms. We process your data for the following purposes

The following is a description of the ways in which We intend to use your personal data.

To perform our contract with you and to support and maintain that relationship. This includes the following:

• To register you as a potential or new customer;

• to process and deliver your order, including managing payments, fees and charges, and collecting and recovering amounts owed to us;

• to record any specific needs or modifications you have or require from time to time, such as text to speech, large print or medical reasons, which will allow us to better assist you in understanding our products and services;

• As part of our recruitment activities.

Comply with legal and regulatory requirements. These requirements include the following:

• confirming your identity for regulatory purposes;

• to detect and prevent fraud;

• to comply with our data protection obligations.

For specific business purposes so that we can provide you with the right products and services and provide you with a safe experience. Our business purposes include the following:

• To manage our relationship with you, including notifying you of changes to our terms and conditions or privacy statement and/or asking you to leave a review or complete a survey;

• to send you newsletters, to keep you informed of new products or services or to recommend other goods or services that may be of interest to you, to keep you informed of special offers, and to invite you to our events;

• to manage and protect our business and our Website (including troubleshooting, testing, system maintenance, reporting and hosting).

• to manage and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);

• to deliver relevant Website content and advertisements to you and measure or understand the effectiveness of those advertisements;

• to use data analytics to improve and develop our Website, products/services, marketing, customer relationships and experiences;

•to use data analytics to improve and develop our Website, products/services, marketing, customer relationships and experiences.

• to monitor or record communications (such as telephone and video calls) with you to resolve questions or problems and also for training and quality purposes and;

We may use AI technologies and Internet of Things “IoT” data, including machine learning, to perform certain activities. Where this is the case, the output is subject to human oversight and review, and we will not include your personal data in data analysis using a third-party model without notifying you. When we use publicly available models for general business purposes, we will give you the option to be anonymized or omitted from the data provided. We will always strive to use AI technologies in accordance with laws, guidelines and government policies.

Change of purpose

We will use your personal data only for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. We may also process your personal data in connection with an acquisition or sale. If this occurs, you will be notified of any change in processing or data controller as a result of this activity. You have the right to object to the processing of your personal data for some of the business purposes listed above, but doing so may affect Our ability to provide some or all of Our services to you. If We need to use your personal data for an unrelated purpose, We will notify you and explain the legal basis that allows Us to do so. Please note that We may process your personal data without your knowledge or consent, in accordance with the above rules, if required or permitted by law.

5. How we secure your information

We are committed to maintaining the confidentiality of the personal information we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure. When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal data is kept secure and protected from unauthorized or inadvertent access, processing, copying, modification, deletion, loss or use.

6. With whom we share your information and why

We do not sell your personal information and generally do not give your personal information to third parties, but there are some exceptions. We may share your personal information in the following ways (if applicable):

• Companies within the Culligan Group

o For administrative, analytical and statistical purposes;

o For testing the information systems operated by our companies;

o for producing a consolidated view of our relationship with you in order to improve the services we can offer you;

o for sending you marketing communications that you have chosen (consented) to receive, or that we believe may interest you based on the services you receive from us or other companies in our group;

o for delivering service messages relevant to our relationship with you;

o for handling complaints and fulfilling the rights of data subjects (such as the right to access).

• Companies appointed by Culligan (these third parties may be located in countries outside of Belgium or the EU)

o with third parties or service providers who provide additional data about you to better enable us to design and develop new products and services to be marketed and sold that meet the needs of consumer groups we have identified and are targeted accordingly;

o with collection agencies to track and collect debts;

o with payment service providers to make payments;

o with our accountants to prepare tax statements and to support statutory reporting;

o with our appointed legal or regulatory advisors or accountants;

o with information technology and information security vendors;

o mwith third parties or service providers to conduct market research on our behalf to help us improve and develop the products and services we provide to you and our other customers;

o with a potential buyer (or its advisors), for due diligence purposes, if we are considering a sale of part or all of our business. For example, in the event of a merger, acquisition, divestiture, change of control or liquidation of Culligan or part of its business (or in anticipation of such an event), we may share your personal information as part of that transaction if necessary to fulfill our obligations in this Statement.

• Organizations and parties appointed or authorized by you

• Legal authorities

o for the purpose of preventing or detecting wrongdoing and/or apprehending or prosecuting offenders, we may share any personal data we collect with law enforcement agencies, other public or private entities, government agencies or representative bodies in accordance with relevant law to comply with a legal obligation or as otherwise permitted by law. This includes government agencies, insurance companies, finance companies and/or other entities.

7. Data retention

We will retain your personal data only as long as necessary to fulfill the purposes for which We collected it, including to comply with legal, accounting or reporting obligations. Where processing is based on your consent, We will only process your personal data until you withdraw your consent. To determine the appropriate retention period for personal data, We will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which We process your personal data and whether We can otherwise achieve those purposes, and applicable legal requirements. We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Notice.

8. Contact Us

If you have any questions about this statement, would like more information about our privacy policy or would like to make a complaint about the way we have handled your personal data, you can contact our data protection officer who will investigate the matter.