Privacy Notice

Last Revised: January 1, 2024

 

 

Contacting Us

 

Copeland LP is registered in the USA as a corporation in the State of Delaware and has its registered office at 8100 W. Florissant Avenue St. Louis, MO 63136, USA.

A list of Copeland’s subsidiaries and affiliates can be found here.

The Copeland subsidiary or affiliate responsible for the respective processing activity is identified in the applicable documentation pertaining to Your Relationship.

If you want to exercise your data privacy rights as described below or you have any questions about this Privacy Notice, please reach out to our data protection organization:

Email: data.privacy@copeland.com

Regular Mail: Copeland LP 

Attention: Privacy Inquiries 

8100 W. Florissant Avenue, Building A

St. Louis, MO 63136, USA

To opt-out of our use of third-party advertising Cookies, please see the section Cookies below.  You may submit a request to opt-out of sales by clicking on this link: “Do Not Sell or Share My Personal Information.”

If you would instead like to unsubscribe from our marketing communications, please select the unsubscribe link in the footer of our email communication or email us at data.privacy@copeland.com

 

Overview

Our privacy practices may vary among the countries in which we operate to reflect local requirements.

The following table provides an overview of our processing activities under this Privacy Notice. By clicking “Read More” or by scrolling down the page, you will find more detailed information. Kindly note that a Specific Notice may provide additional information which would prevail unless specifically stated otherwise.

Personal Data Collection

Depending on Your Relationship with us, we may collect the following types of Personal Data from you through your interactions with us, either automatically or provided directly by you:

• Contact Information:  including your name, email, username, phone number, company, industry and address, as well as the name and address of the dealer that sold you your product;
• Demographic Information: including your gender, age, citizenship, education, profession, occupation, and income level;
• Financial/Payment Information: such as your credit card number, billing address, shipping address, security code and other payment transaction and verification details, as well as consumer’s application and claims history;
• Analytical Information: including pages and products viewed, items added to your shopping cart, products and services you have purchased from us, ads that you clicked on, emails from us that you opened, browser type, operating system (“OS”), Internet Protocol (“IP”) address and device and geolocation information;
• Publicly available information about you from third-party sources, such as the postal service for shipping address verification;
• Unique Personal Identifiers: Your mobile OS, a mobile device identifier embedded by us, or other commonly used mobile device and unique personal identifiers such as cookies, beacons, pixel tags or similar technology.

In certain circumstances, we collect Personal Data from you about a third party.  If you submit any Personal Data about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Data in accordance with this Privacy Notice.

We also collect your Personal Data or usage data from third parties in certain circumstances:

• Your email address and other collected Personal Data about you may be forwarded to Copeland by a third-party website when you request that Copeland contact you through such third-party website;
• Your Personal Data may be forwarded to Copeland when you choose to participate in a third-party application or feature, such as live chat, one of our social media pages or a similar application or feature on a third-party website;
• Additional Personal Data may be forwarded to Copeland from third parties to combine with the Personal Data we collect through Your Relationship in order to enhance our ability to serve you, to focus content we provide to you and to offer you opportunities to purchase products or services that we believe may be of interest to you based upon the information we have collected.

We will apply the terms of our Privacy Notice to any Personal Data received from a third party, unless we have disclosed to you otherwise.  Copeland is not responsible for these third parties’ dissemination of your Personal Data.

 

How We Use Your Personal Data

Depending on the type of Relationship with us, we use your Personal Data for the following purposes, as permitted by applicable law:

• Purchases: We use your Contact Information and Payment Information to allow us to process and fulfill purchases you make through Your Relationship.
• Customer Service: We use your Contact Information to receive and respond to your questions about products, services or warranties and to communicate with you about contests, surveys or sweepstakes. To address your questions, we may also request your industry and/or the name and address of the dealer that sold you our product.
• Use of Product: For certain products and as specifically disclosed in a Specific Notice, we may require your username and email address to use the product.
• Feedback: We use your username, email address, products purchased, and other user-generated content you may provide when you rate and review our products. Your feedback helps us develop new products and services, maintain quality assurance and debug issues you may identify.
• Website Registration: We may use your Contact Information and Demographic Information when you create an account through any of our services in order to provide you a more personalized user experience.
• Analytics: When you use our services (e.g., our website), we may automatically collect and use Analytical Information (where permissible by law) in order for us to continually improve your experience with our services and to target marketing and advertising of our products to you.
• Marketing: We may use your Personal Data to determine what products may be of interest to you, provide you with marketing communications (if you have opted-in to receive such communications or otherwise where permitted under applicable law) and to conduct market research. We may also use information you provide us, including your industry, whether you own our product, experience with our products, and user-generated content, for these marketing purposes.
• Location-Based Services: For certain products and as disclosed in a Specific Notice, we may use your current location, provided address and/or zip code to provide you the location of the retailer of our products or other appropriate information.

 

Legal Bases for the Processing and Consequences

We rely on the following legal grounds for the collection, processing, and use of your Personal Data:

• Contract: the processing is necessary to provide the products or services as requested by you or for the performance of a contract to which you are a party (or to take steps at your request prior to entering into a contract);
• Consent: the processing is based on your consent for one or more purposes (e.g., marketing);
• Legal Obligation: the processing is necessary for compliance with our legal obligations (e.g., complying with law or subpoenas);
• Legitimate Interest: the processing is necessary for the purposes of our legitimate interests or those of a third party (e.g., improving your experience with our websites and products) except where overridden by your fundamental rights and freedoms that would require protection.

In general, the provision of your Personal Data is voluntary, but in certain cases it is necessary in order to enter into a contract with us or to receive our products or services as requested by you.

 

Personal Data Shared with Third Parties

We only share your Personal Data with companies, organizations and individuals outside of Copeland as described below or as described in a Specific Notice.

• Recipients within Copeland: Depending on the categories of Personal Data and the purposes for which the Personal Data has been collected, different Copeland entities and the internal departments within these entities may receive your Personal Data. For example, our IT department may have access to your account data, and our marketing and sales departments may have access to your account data or data relating to product orders. Moreover, other departments within Copeland may have access to certain Personal Data about you on a need-to-know basis, such as the legal and compliance department, the finance department or internal auditing.
• Copeland Affiliates: We may share your Personal Data with Copeland’s affiliates and business partners that distribute our products, including our unaffiliated dealers, manufacturers and suppliers in order for these companies to contact you about their products, services or other offerings that may be of interest to you. 
• Service Providers: We may share your Personal Data with companies that perform tasks on our behalf related to our business. Such tasks may include processing transactions, locational services, analyzing website or mobile application usage data, electronic and postal mail service, contests/surveys/sweepstakes administration, or marketing services. Third-party service providers receive your Personal Data as necessary to perform their role, and we instruct them not to use your Personal Data for any other purposes.
• As Required or Appropriate by Law: We will use or disclose your Personal Data if required or authorized by applicable law as necessary to (without limitation) comply with legal processes or respond to requests from government authorities, enforce our terms and conditions or investigate violations of them, to detect, prevent or address fraud, security or technical issues, or to protect our operations or those of our affiliates, protect the rights and safety of Copeland, its affiliates or individuals.
• Business Transfers: As we continue to develop our business, we might sell, buy, merge or reorganize brands, stores, subsidiaries or business units. In this regard, we may share your Personal Data with a third party in such transactions if and to the extent permitted by applicable law. Customer information generally is one of the transferred business assets, but remains subject to any preexisting applicable Privacy Notice.

We may share aggregated data that has been anonymized or pseudonymized (so that you are not identified) with third parties – like publishers, advertisers or connected websites – and may make this data publicly available or use it for any purpose.

Disclosure or Sale of Personal Data

The following table identifies the categories of Personal Data that we disclosed for a business purpose to service providers or sold to third parties in the 12 months preceding the “Last revised” date of this Privacy Notice and, for each category, the category of service providers or third parties to whom the Personal Data was sold or disclosed:

Public Forums

Our websites may offer publicly accessible blogs, message boards, or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

Links to Social Networking and other Third-Party Websites

Our services may contain links to social networking and other websites and mobile applications that are operated and controlled by third parties. While we try to link only to websites that share our high standards and respect for privacy, we do not take responsibility for the content, or the privacy practices employed by other websites. Unless otherwise stated, any Personal Data you provide to any such third-party website will be collected by that party and not by us and will be subject to that party’s privacy policy (if any), rather than this Privacy Notice. In such a situation, we will have no control over, and shall not be responsible for, that party’s use of the Personal Data you provide to them.

 

Security

We maintain appropriate technical and organizational measures to protect your Personal Data, including assuring that third-party service providers who access or handle Personal Data on our behalf and affiliates maintain such safeguards. We seek to encrypt credit card numbers from e-commerce transactions conducted on our websites using secure socket layer ("SSL") technology.

However, no method of Internet transmission or electronic storage is 100% secure or error-free, so it is not possible to guarantee absolute security. You must protect against unauthorized access to your password and to your computer, and be sure to sign off when finished using a shared computer. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please immediately notify us by email data.privacy@copeland.com.

Where we have given you or you have chosen a password which enables you to access certain portions of our websites, you are responsible for keeping this password confidential. You should not share your password with anyone.

International Data Flows 

As Copeland is a global organization, the Personal Data that we collect or receive about you may be transferred to and/or processed in accordance with applicable law by entities that are located inside or outside the local jurisdiction it is collected in. The laws of these jurisdictions may differ from the laws of your country. Regardless, we take necessary measures to ensure that transfers out of the local jurisdiction are adequately protected as required by applicable data protection laws, such as adopting the European Commission’s Standard Contractual Clauses or another safeguard to enable the transfer in accordance with applicable law. You can ask for a copy of such appropriate safeguards by contacting us as stated above under the section Contacting Us. 

 

Your Choices and Rights

Depending on your location and applicable law, you may have certain rights in relation to your Personal Data, as described below. To exercise these rights, please contact us using the information provided in the Contacting Us section above.

• Right to Access, Correct, Update and Portability: You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. You may have the right to obtain a copy of the Personal Data undergoing processing in a structured, commonly used and machine-readable format and you may have the right to transmit the data to another entity without hinderance from us. For further copies requested by you, we may charge a reasonable fee based on administrative costs. In the event Personal Data concerning you is inaccurate, you may have the right to have it corrected, and in some cases completed by means of providing a supplementary statement.
• Deletion: Under certain circumstances, you may have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data.
• Objection to or Restriction of Processing: Under certain circumstances, you may have the right to object to the processing of your Personal Data by us, or request that we restrict the processing of your Personal Data. In such case, the respective data will be marked and may only be processed by us for certain specific purposes, or not at all (especially in the case of profiling to better understand your interests or for marketing). Furthermore, under certain circumstances with respect to automated individual decision-making, you have the right to obtain human intervention, express your point of view, and contest the decision. You also may have the right to lodge a complaint with the competent data protection supervisory authority.
• Opt out: In case you have given us your consent for direct marketing purposes (e.g., you actively subscribed to our newsletters) you can withdraw your consent with future effect by contacting us. You may also have the right to opt-out of the sale of certain types of personal information under applicable law.

Please note that requests to exercise your rights with us may be subject to verification of the identity of the requester. How we verify your identity will depend on the manner and context in which your data was collected. You may be entitled to use an authorized agent to exercise your rights on your behalf, and if you choose to do so, the agent will be required to verify both their identity and their authority to act on your behalf. 
 

South Africa Residents

For our privacy statement and access to information manual applicable to South Africa, please contact data.privacy@copeland.com.

How Long We Keep your Data

Your Personal Data will be kept as long as necessary to provide you with the services and products you requested. Once you have ended Your Relationship with us, we will either delete or anonymize your Personal Data, unless a statutory retention requirement applies (e.g. for tax purposes, compliance with laws or in regards to a legal claim). To the extent possible, we will restrict the processing of your Personal Data for such limited purposes after the termination of Your Relationship and on a need-to-know basis only.

Notice to Employment Applicants

Certain pages of our websites include the ability for people interested in working for Copeland or one of its subsidiaries or companies to find out more information about employment opportunities at Copeland, its affiliates and/or subsidiaries. To apply for open positions using our website, you must create an employment profile through the company's career site, which includes the information that Copeland requests you to provide, and that you may choose to provide, to be considered for employment (the “Employment Applicant Information”).

Prior to creating an employment profile, you must affirmatively consent to the privacy terms governing the submission of your information to Copeland for employment purposes on the Copeland career page. The terms that you agree to in order to create an employment profile shall govern Copeland’s use of the information you provide to apply for employment. Copeland will use Employment Applicant Information for evaluation and hiring purposes, and communication in furtherance of the evaluation and hiring purposes.

Children

In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, our website does not permit children under 13 years of age to become users, and we do not intentionally collect information from children. By using our website, you represent that you are 13 years of age or older.

Cookies

We use “cookies,” a small text file transferred to your device, along with similar technologies (e.g., internet tag technologies, web beacons and embedded scripts) to help provide you with a better, more personalized user experience. To learn more about how we use cookies and to change your cookie settings, please click here.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked.  Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.  

Google reCAPTCHA

We utilize Google reCAPTCHA, which is a free service that protects websites from spam and abuse using advanced risk analysis techniques to tell humans and bots apart. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Use.  More information as to Google reCAPTCHA and how it works is available here.

California Privacy Notice

 

This California Privacy Notice supplements the information contained in our Privacy Notice and applies solely to individual residents of the state of California (“consumers” or “you”). Under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA") (collectively, "California Privacy Law"), Copeland is required to provide you with a privacy notice in a specified format. If you are a consumer as defined by California Privacy Law, please review this section below as it is version of privacy notice applicable to your personal information as an individual or business ("California Personal Information").  If you are a California resident, please note the following about how we have collected, used, disclosed, and otherwise processed your personal information over the past 12 months, as well as additional rights you may have with respect to your personal information. This Privacy Notice does not reflect our processing of California residents' personal information where an exception under California law applies.

For the purposes of this California Privacy Notice, Personal Information does not include:

• Publicly available information from government records.
• Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
• Lawfully obtained, truthful information that is of public concern.
• Information excluded from the scope of California Privacy Law.
• Information reflecting communications or transactions between us and representatives of our business customers and other third-party entities in connection with us considering, providing or receiving a product or service to or from the business customer or other third-party entity.

California Personal Information. 

Consistent with the section "Personal Data Collection" above, we may collect certain categories of information about California residents, such as:

• Identifiers:  including your name, email, username, phone number, company, industry and address, as well as the name and address of the dealer that sold you your product;
• Personal information: including, in addition to identifiers and other data mentioned, your age, education, profession, occupation, income level, credit card number, billing address, shipping address, security code and other payment transaction and verification details, as well as consumer’s application and claims history;
• Characteristics of protected classifications: including gender, and citizenship; 
• Commercial information: including purchase history;
• Internet or other electronic network activity information: including pages and products viewed, items added to your shopping cart, products and services you have purchased from us, ads that you clicked on, emails from us that you opened, browser type, and operating system (“OS”);
• Geolocation data: Internet Protocol (“IP”) address and device and geolocation information;
• Audio, electronic, visual or similar information, including in connection with use of Copeland systems, such as voicemail, as well as CCTV and security monitoring systems;
• Inferences: Your mobile OS, a mobile device identifier embedded by us, or other commonly used mobile device and unique personal identifiers such as cookies, beacons, pixel tags or similar technology; and
• Publicly available information about you from third-party sources, such as the postal service for shipping address verification.

 

Certain California Personal Information that we collect about you may be considered sensitive personal information within the meaning of California Privacy Law, including: credit card information (for billing and transactional purposes in connection with providing products and services) and precise geolocation information. We only use and disclose sensitive personal information as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.

Sources.

We generally source California Personal Information directly from you (for instance, when you provide information as part of a business transaction or otherwise), third party reference agencies, distributors and intermediaries, distributors and intermediaries, data analytics providers, and social media networks.

Purposes of Use.

In addition to the purposes stated above in the section How We Use Your Personal Data, we currently collect and use the California Personal Information for the following business purposes:

• Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device; and
• Fulfilling our services, including completing transactions.

In addition to the purposes stated above in the section How We Use Your Personal Data, we currently collects and uses the California Personal Information for the following commercial purposes:

• Advertising, marketing, and public relations (including direct marketing);
• Market research and competitor analysis;
• To display personalized advertising when you visit our Sites or a third party website; 
• To contact you with special offers and other information we believe will be of interest to you;
• To invite you to participate in surveys and provide feedback to us; 
• To better understand your needs and interests; and
• To improve our marketing and promotional efforts.

Disclosure of California Personal Information. 

We may disclose the categories of California Personal Information described above for the business purposes described above to:

• Affiliates. For example, we may disclose California Personal Information between and among Copeland entities and its current and future parents, affiliates, subsidiaries, brands and other companies under common control or ownership;
• Third party service providers that perform data processing activities on our behalf, and subject to appropriate privacy and security obligations;
• Customers, distributors, and intermediaries in connection with the performance of transactions; 
• Government and other authorities as required by law; 
• Auditors and advisors for the performance of audit functions and advisors for the provision of legal and other advice.
• Potential purchasers and other parties in connection with the sale, purchase or merger of a business; and
• Others to the extent necessary to comply with applicable law and/or as otherwise permitted under California Privacy Law.

We may disclose Identifiers, Internet or other electronic network activity information, and Geolocation data for the commercial purposes described above to:

• adtech providers;
• social media;
• and analytics providers. 

We do not sell (as this term is defined under California Privacy Law) the California Personal Information of consumers we know to be less than 16 years of age as we do not knowingly collect data of a minor.

Data Retention.

We keep your California Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). We may remove your California Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Once you have ended Your Relationship with us, we will either delete or anonymize your California Personal Information, unless a statutory retention requirement applies (e.g. for tax purposes, compliance with laws or in regards to a legal claim). To the extent possible, we will restrict the processing of your California Personal Information for such limited purposes after the termination of Your Relationship and on a need-to-know basis only.

California Privacy Rights.

California residents have certain rights with respect to their California Personal Information collected by businesses. If you are a California resident, you may exercise the following rights regarding your California Personal Information by clicking here, subject to certain exceptions and limitations:

• Deletion of your California Personal Information;
• Correction of inaccurate California Personal Information that has been collected about you;
• The right to know/ access the categories of California Personal Information that we collect about you, including:
  • the specific pieces of California Personal Information;
  • the categories of California Personal Information we have collected about you;
  • the categories of sources from which we have collected California Personal Information about you;
  • the categories of California Personal Information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • the categories of California Personal Information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
  • the business or commercial purposes for collecting or, if applicable, selling California Personal Information about you.
• The right to direct us not to sell or share California Personal Information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
• The right to non-discrimination. We will not discriminate against California residents if they exercise any of the rights provided in California Privacy Law as described in this section. As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

In some instances, we may decline to honor your request.  For example, we may decline to honor your request if we cannot verify your identity or confirm that the California Personal Information that we maintain relates to you. In other instances, we may decline to honor your request where an exception under California Privacy Law applies, such as where the disclosure of California Personal Information would adversely affect the rights and freedoms of another consumer. We will respond within 45 days of receiving your request, unless we request an extension. In the event a 45-day extension is needed, we will notify you of the extension within the initial 45-day period.

If you are a California resident, to make a request described above relating to the California Personal Information that we collected [or shared with third parties] about you that is not subject to an exception under California Privacy Law, you may:

• contact data.privacy@copeland.com

To Exercise Your Right to Opt-Out of the Selling and/or Sharing of Your California Personal Information

In addition to the above, California residents have the right to opt-out of the sharing and sale of their California Personal Information, as such terms are defined under California Privacy Law. To exercise this right, you may submit a request via email to data.privacy@copeland.com.  In addition, we have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control ("GPC") within the browser. Due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different websites or digital apps following your visit to one of our Sites.

Authorized representative.  You can designate an authorized agent to make a request under California law on your behalf in certain circumstances. If you use an authorized agent for this purpose, we may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with California law.

You will not be penalized for exercising your rights to your personal information. And, if we deny your request, we will explain why.

Shine the Light Law.   California residents are entitled once per year to request and obtain certain information regarding our disclosure, if any, of your personally identifiable information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an email to data.privacy@copeland.com with the subject line “Shine the Light Request” and your full name, email address, and postal address in your message. In response to your request, we will provide you with a notice describing the cost-free means to opt-out of our sharing your personally identifiable information with third parties with whom we do not share the same brand name, if the third party will use it for their direct marketing purposes.

Financial Incentive. We do not engage in providing financial incentives for the disclosure of Business Information.
 

Accessibility

We are committed to ensuring this Privacy Notice is accessible to individuals with disabilities.  If you wish to access this Privacy Notice in an alternative format, please contact us as stated above under the section Contacting Us.

Changes

We may update this Privacy Notice from time to time. We will notify you of any such changes, including when they will take effect, by updating the “Last revised” date above or as otherwise required by applicable law.