ECR International, Inc. Privacy Policy

This privacy policy ("Privacy Policy") is a legal agreement between you and ECR International, Inc. and its affiliates ("ECR International, Inc.", "we", "our", "us") for the use of certain ECR International, Inc. websites, systems, and software.

Summary
This Privacy Policy describes the information we collect and how we use it. If you have questions, please refer to the full text version of the Privacy Policy below.

We request personal information from you (including name, address, telephone number, e-mail address and, when necessary, customer number) when you request information from us, request to be included in our dealer listings, and register ECR International, Inc. products in our warranty database.

We use your data to provide the services you request, improve our products and services, and to provide you with information on our products and services (you can always opt-out from this).

We will take reasonable measures to secure your data, and we store it on our systems for as long as you remain a customer or for legal reasons. You can access your data by contacting us using the information below.

We do not share your data with anyone outside ECR International, Inc., unless we are required to do so by law or as provided in the full text version of the Privacy Policy.

If you have any additional questions or feedback regarding this Privacy Policy, contact us at:

ECR International, Inc.
World Headquarters
2201 Dwyer Avenue, Utica, NY 13501
Phone: (315) 797-1310
Fax: (315) 797-3762
Email: marketing@ecrinternational.com

Introduction
At ECR International, Inc., we know understanding our customers' needs and expectations for products, services and information is an important part of building an enjoyable, interesting and satisfying long-term relationship. We've created this Privacy Policy so you can have easy access to information about our privacy practices and how we use the information we may collect. Personal information for the purposes of this Privacy Policy means information that can be used to personally identify you or is associated with any such information, or personal information may be defined by the laws of the location where you live.

You acknowledge that this Privacy Policy is part of our terms of service (the "Terms of Service") and by accessing or using ECR International, Inc.'s websites, the ECR International, Inc. App, or ECR International, Inc. products or services, you agree to be bound by both this Privacy Policy and the Terms of Service. If you do not agree to abide by both this Privacy Policy and the Terms of Service, please do not use the ECR International, Inc. websites, the ECR International, Inc. App, or ECR International, Inc. products or services.

What Information We Collect, and How We Use the Information We Collect We request information from you (which may include your name, address, telephone number, e-mail address and, when necessary, customer number) when you:

Enter ECR International, Inc. product warranty information into our website.
Request information from us.
Request to be included in our dealer listings.
Send us an e-mail.
The information we collect enables us to:

Process your product warranty.
Provide the services you request.
Contact you about the status of warranty.
Send you newsletters, catalogs or promotional offers we believe will be of interest to you (if we have obtained your consent where required by law, and you can always opt out of this).
Personalize our communications to you.
Provide information concerning products you have purchased.
If you register an account through a ECR International, Inc., ECR International, Inc. may collect the following data:

Data required to create a user account (name, postal address, zip code, and contact details such as your email address and phone number). Data from your user account (name, address, email, country and zip code) may be used to inform you about new products and services from ECR International, Inc. that might be of interest. You can always opt-out from this. ECR International, Inc. routinely records technical information such as IP addresses and browser type and version when the browser or mobile device contacts ECR International, Inc. servers. This information is used for troubleshooting and is stored on servers which may be located outside of your country of residence. When you create a user account, ECR International, Inc. collects and stores your email address, which from that point forward is used for communication purposes relating to services and products from ECR International, Inc. ECR International, Inc. may send an e-mail to confirm orders you place online, RMA and warranty submittals. We may use e-mail to contact you with questions regarding your input. We use e-mail to answer your online questions to us or requests for information. We send e-mail newsletters containing promotions of products and services, news, and information about upcoming events (if you have opted in, where required by law). We do not share your e-mail address with any other business or organization. Occasionally, we may contact you via e-mail to ask for permission to reprint what you have written, as a testimonial, for use on our website or in our printed materials.

Sharing Information with Others
As a general rule, we do not sell or share your personal data with anyone outside ECR International, Inc., unless we are required to do so by law or as provided in this Privacy Policy. Under no circumstance does ECR International, Inc. sell or share your personal data with third parties for commercial or marketing purposes.

The following are the limited situations where we may share your personal data: We may share your personal data with trusted third parties that perform business functions (e.g. hosting and/or operating our websites, analyzing data or technical monitoring of our systems) or provide services on our behalf (e.g. support services). All such third parties will be required to adequately safeguard your personal data and only process it in accordance with our instructions. Sometimes ECR International, Inc. offers you a service in cooperation with other companies. In such cases, we may exchange your personal data with these companies to allow you to make optimal use of our combined services. ECR International, Inc. will only do so when we consider that the third parties will provide a welcome additional service and we will only share your data with these companies with your prior consent. Upon the sale or transfer of ECR International, Inc. and/or all or part of its assets, your personal information may be among the items sold or transferred. ECR International, Inc. may share non-personal information publicly and with our partners. For example, we may publish trends about energy use in the home. This information may also be shared with other end users to help them better understand their energy usage compared to others or help us generally improve our system. We may also share this information with energy companies, for example, if they are interested in providing demand-response services. We take steps to keep this non-personal information from being associated with specific end users and we require our partners to do the same. We may also disclose your personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (ii) to enforce or apply our Terms of Service and other agreements, including for billing and collection purposes, and (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ECR International, Inc., our customers, or others.

Your Access to Information
You can request access to and have the opportunity to modify or delete personal information by contacting us using the information below. For security reasons, we reserve the right to take steps to authenticate your identity before providing access to your personal data. Subject to applicable law, we may charge you a small fee to access your personal data. We will provide an individual access to any personal information we hold about them within 30 days of any request for that information. Unless it's prohibited by law, we'll remove any personal information about an individual from our servers at their request. Because of the way we maintain certain services, it may take some time before backup copies are erased, and we may retain certain data if we are required to do so for legal reasons.

Data Privacy Rights for Individuals in California

The California Consumer Privacy Act (CCPA) provides California residents with certain rights regarding their personal information. This section describes those rights and explains how they may be exercised by those subject to the CCPA.

Data Access, Deletion and Portability Rights

In addition to the right to certain information as set forth in this Privacy Policy (including the categories of personal information that we collected from California residents over the prior twelve months, categories of sources for that information, and the purpose for which such information was collected, which are all listed above), you have the right to request, not more than twice in any twelve-month period, that we disclose certain information to you about our collection and use of your personal information. Upon our confirmation of a verifiable consumer request, we will disclose to you, as applicable:
the categories of personal information that we collected from you; the categories of sources of personal information that we collected about you; our business or commercial purpose for collecting or selling your personal information; if we sold or disclosed your personal information to a third party for a business purpose: 1) for sales, identify personal information categories that each category of third party recipient(s) purchased and/or 2) for disclosures pursuant to a business purpose, identify the personal information categories that each category of third party recipient()s obtained. the categories of third parties with whom we share that personal information; the specific personal information that we collected about you; You may also request deletion of your personal information. Upon our confirmation of a verifiable consumer request, we will delete your personal information and/or direct our service providers to delete the information unless we need to retain the information and are permitted to do so by law.

Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. That is, unless otherwise permitted by law, we will not:
deny you goods or services;
charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
provide you with a different level of goods or services;
Pursuant to the CCPA, however, there may be circumstances when we may offer you certain financial incentives as compensation for collecting, selling or deleting personal information, which will reasonably relate to your personal information's value. We may also offer a different price, rate, level or quality of goods or services to consumers where the price or difference is directly related to the value provided to us by the consumer's personal information. We will provide you with written terms that explain the material aspects of any such incentive program. Participation in such a program requires your prior opt-in consent, which you may revoke at any time.

How to Exercise Data Access and Data Portability Rights

To exercise the data access and portability rights described in this section, please submit a verifiable request to us by contacting us at:

marketing@ecrinternational.com
https://ecrinternational.com/contact
You may make a request for data access or portability twice within a twelve-month period. The verifiable consumer request must:
provide sufficient information to allow us to reasonably verify that you are the person about whom we collected and/or shared personal information; and describe your request in sufficient detail to allow us to understand and respond to it. If you fail to comply with the foregoing requirements, we will be unable to provide you with any personal information that is in our possession. Any personal information provided in connection with a request to exercise your rights under the CCPA will only be used for identity verification purposes.

Data Privacy Rights for Individuals in the European Union and/or the European Economic Area In addition to your right to certain information contained in this Privacy Policy, pursuant to the General Data Protection Regulation, you have the following rights regarding your personal data that we hold:
be informed of our intent to transfer your personal information to another country or international organization, the recipients of that information, and where information regarding the applicable privacy safeguards may be obtained;
request access to your personal information;
request correction of your personal information if it is incorrect;
request that we delete or stop processing your personal information under certain circumstances;
object to our processing of your personal information under certain circumstances;
request that we restrict our processing of your personal information, and where our processing is based on your consent, withdraw that consent (which may be done by emailing: marketing@ecrinternational.com) without affecting the lawfulness of processing based on consent before its withdrawal;
request that we transmit your personal information either to you or another service provider under certain circumstances (costs may apply);
be informed of your right to complain to a supervisory authority if you feel that we have not complied with applicable laws regulating your personal information (contact information for supervisory authorities may be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. For more information, or to make a request, please email: marketing@ecrinternational.com with your name, email address, request, and basis for your request.

Security and Retention of Information
ECR International, Inc. will make reasonable efforts to ensure that your personal data are properly secured using appropriate technical and organizational measures, so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss. We will retain your information for as long as your account is active or as long as needed to provide you services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements. We do collect and retain "aggregate data," that is, group data with no personal identifiers, which is used to help us understand how the mobile application is being used and to improve its usability, and we also use aggregate data to enhance the quality and availability of the heating system products and services we offer.

As described above, some information is processed and stored directly on ECR International, Inc. room thermostats. You can delete the information on your room thermostat by resetting it to the defaults.

Notice of Breach of Security
Nobody is safe from hackers. If a security breach causes an unauthorized intrusion into our system that materially affects and/or presents a real risk of significant harm to you, then ECR International, Inc. will notify you and required others as soon as possible in accordance with applicable legal requirements.

Privacy of Children
ECR International, Inc. systems, software and services are not intended for use by children under the age of 18, and we do not knowingly collect personal information from anyone under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at marketing@ecrinternational.com.

Automatic Information Collection and Tracking Technologies
ECR International, Inc. may use cookies to deliver content specific to your interests and to improve the convenience and efficiency of your experience when using our products and services. A cookie is a piece of data stored on the user's hard drive tied to statistical information about the user. You can always choose to not accept cookies, but you may not be able to use some of the ECR International, Inc. products and services. ECR International, Inc. may also use web beacons, which are small electronic files, to track certain app statistics, such as recording the popularity of certain app content, and verifying system and server integrity.

Some of our business partners (e.g., advertisers or tracking utility companies) may use cookies on our sites. We do not have access or control over these cookies. For example, our website utilizes Google Analytics, a common website analytics tool. For more information about Google Analytics, please refer to the website, "How Google uses data when you use our partners' sites or apps" at http://www.google.com/policies/privacy/partners/.

We do not track our visitors across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your internet browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

Social Media Platforms and Other Websites
ECR International, Inc. may include social media features in conjunction with its products and services, like links to our Facebook or Twitter pages. These features may collect information about your IP address and which page you're visiting on our site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. We also maintain presences on social media platforms like Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them. Location of Information
ECR International, Inc. has servers and offices located in the United States and in the United Kingdom, so your information may be transferred to, stored, or processed in both the United States and/or the United Kingdom. By using the ECR International, Inc. system, services, and software, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States, United Kingdom, and those third parties with whom we share it as described in this Privacy Policy.

No Liability
You understand that electronic communications may be accessed by unauthorized parties when communicated across the internet, network communications facilities, or other electronic means. You agree that we are not responsible for any electronic communication and/or any of your data which may be lost, altered, intercepted or stored without authorization during the transmission of any data whatsoever across networks not owned and/or operated by us. We do not guarantee that your information will not be misused or disclosed to third parties. We will not have any liability to you for any such misuse or disclosure.

Changes to this Privacy Policy
This Privacy Policy may be updated periodically and these changes may affect the way we use your personal information. We encourage you to periodically review this page to stay informed about how we use your personal data.

Consent
By using our products or services, you consent to the collection and use of your information as set forth in this Privacy Policy. Except as required or allowed by law, we will not use or disclose your personal information for any purpose for which you refuse us consent or later withdraw your consent. If you withdraw consent, you agree that in spite of this withdrawal we may continue to use the personal information previously provided to us to the extent that we are legally or contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have to us. You also understand that although you can use our products and services for some purposes without providing us with any personal information, we need personal information about you for some services, including those that involve an ongoing relationship with us. If you refuse to provide us with the information we require or later withdraw your consent to use and disclose this information, we may no longer be able to provide you with these services.

Questions
If you have any questions regarding this Privacy Policy please inform us by contacting:

ECR International, Inc.
World Headquarters
2201 Dwyer Avenue, Utica, NY 13501
Phone: (315) 797-1310
Fax: (315) 797-3762
Email: marketing@ecrinternational.com

This Privacy Policy was last modified on January 31, 2022.