Privacy Policy

MARKET DISTRIBUTOR WEBSITE PRIVACY & COOKIES STATEMENT 

Last reviewed 26 June 2018

MAINPACK LLC, registration number 30977482 “we”, or “us”) take the privacy of those visiting this website (“you”) (“Website”) very seriously. We are committed to complying with data protection legislation which regulates the processing of your personal information and grants you various rights in respect of this information.    

What does this statement cover?

This Privacy Statement (the “Statement”) describes how we use the personal information which is supplied to us by visitors to the Website, including personal information we obtain when we offer services through the Website (the “Services”). You may only use our Services if you are over 16. Reference is also made to WD-40 Company Limited (“WD-40 Company”).  This is the company which operates the Website. Its corporate HQ address is Brick Close, Kiln Farm, Milton Keynes, MK11 3LJ.

We provide this Statement because you have the right to know what information we collect about you, how it is protected and used, and the circumstances under which it will be disclosed. The Statement also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out at section 11 below.  

We reserve the right to modify this Statement at any time.  If we make material changes to this Statement, we will notify you of this either by email or by means of a notice on the Website; where necessary we will obtain your consent.

1. Information We Collect
2. How We Use Your Information
3. Sharing and Disclosing Your Information
4. Marketing Communications
5. International Data Transfers
6. Security
7. Cookies
8. Links to Other Sites
9. Your Uploaded Content
10. Retention of Information
11. Your Rights
12. How to Update Your Information
13. Contact Information
14. Information We Collect

This Statement explains how we use personal information that we collect from, or which is supplied to us by, Users of our Website. 

We collect and process personal information about you when you interact with us and our Website, and when you purchase goods from us and use our Services. This information includes:

• Your name
• Your gender
• Your age/date of birth
• Your marital status
• Your company, job title and occupation
• Your email address and phone number
• Your postal address
• Your payment information
• Content you provide including photos, audio and/or video (“end user content”)
• Your marketing preferences, including any consents you have given us

WD40 Company as the operator of this website may collect information related to the browser or device you use to access the Website, including log files such as internet protocol (“IP”) addresses, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. See the ‘Cookies’ section below.

Aggregated Data

WD40 Company use data about Users to compile anonymous, aggregated statistics for operational and marketing purposes. Such purposes include benchmarking, determining appropriate levels of hardware, determining the numbers of employees that will be needed to provide the Services to our Users, and reporting numbers of Users that use the Services. This anonymous, aggregated data is not used in any way that can identify an individual User.

2. How We Use Your Information 

We use the information you provide to us for the following purposes:

• As required by us to conduct our business and pursue our legitimate interests, and where our interests are not overridden by your data protection rights, in particular:
  • Responding to your queries.
  • To support your participation in competitions and surveys. 
  • To assist us in providing better products and Services: for example, to evaluate the performance of our staff, to assess the quality of our products and Services and to help us improve our Website, facilities and Services. 
  • Ensuring the security of our websites and information technology systems and protecting our rights.
  • We will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation) 
  • If you provide a credit or debit card as payment, we use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud. 
• Where you give us your consent:
  • We will send you direct marketing in relation to our relevant products and Services, or other products and services provided by us, our affiliates and carefully selected partners. If you want to stop receiving marketing materials from us, please tell us. Section 4 of this Statement explains how you can do this.
  • WD-40 Company place cookies and use similar technologies and will do this in accordance with the cookie section of this Statement and the information provided to you when those technologies are used
  • We may use images that you provide to us on our website and otherwise in our marketing materials to promote our products 
  • On other occasions where we ask you for consent, we will use the information for the purpose which we explain at the time.  
• For purposes which are required by law:
  • In response to requests by government or law enforcement authorities conducting an investigation. 
• To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us or enter a competition we run. This includes:
  • Fulfilling your orders and taking payments from you.
  • Providing customer service related to your interactions with us or to respond to your enquiry.
  • Arranging the delivery or other provision of products, Services or prizes. 

3. Sharing and Disclosing Your Information

WD-40 Company may disclose aggregated user information about how the Website is used with us and may use personal information relating to you to customise the advertising and marketing messages you receive on the Website, or may work with outside companies to do so (e.g. Facebook).  Aggregated data may be shared with these companies so this customisation can be achieved. Anonymous click stream, number of page views calculated by pixel tags and aggregated demographic information will also be shared with our advertisers and business partners (e.g. Google).

WD-40 also use data regarding your visit to the Website to perform statistical analysis in order to measure interest in, and use of, the various areas of the Website. It will share such information with relevant advertisers or external parties. We will, however, provide only aggregated data from these analyses to third parties, not specific Users’ data.

Personal information will be shared with third party service providers (including technology consultants and CRM vendors), who, in the course of providing services to us, will be given access to the information you have provided to us and will process it on behalf of us and WD-40 Company for the purposes identified above. Such third parties include providers of website hosting, maintenance, and technology and CRM services. Each of these service providers is contractually obliged to provide services to us in a manner consistent with this Statement.

Our employees, agents and contractors must have a business reason to obtain access to your personal information. We share also your personal information with those who help us manage or provide the Services (e.g. message board administration, statistical analyses, data processing, and order fulfilment), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfilment aspects of contests and promotions. These outside contractors or agents will only use your personal information to provide us with a specific service and not for any other purpose. 

If, in the future, we wish to share your personal information with third parties acting other than as our agents or service providers, we will tell you about this and provide you with the opportunity to opt-out.

In the event that the business is sold, integrated with and/or transferred to another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Your personal information will be disclosed where disclosure is necessary in order for us to comply with a legal obligation or is otherwise necessary in order for us to  protect our rights, the rights of our affiliated companies, the rights or safety of any individual or the public, and rights of our Users or any third party. 

4. Marketing Communications

From time to time, we would like to send you by email information about other similar WD-40 Company products or services which we think will be of interest to you (including, for example, newsletters and promotional communications). We will do this only if you agree and you have a right to object to receiving this information from us, or profiling we carry out for direct marketing, at any time. You can do this by: 

• Following the opt-out instructions included in each email communication we send you; or 
• Contacting us using the contact details at section 13 below. 

5. International Data Transfers

We do not transfer your personal information to countries outside your home country except with WD-40 Company. However, if this changes, we will tell you.

6. Security

We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. 

We follow generally accepted industry standards to protect personal information submitted to us by Users, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Cookies

WD-40 use cookies to make the Website easier to use and more useful. When you visit the Website our servers send a cookie to your computer. By themselves, cookies do not personally identify you, but instead simply recognise the web browser you are using. 

There are two types of cookies: session and persistent. Session cookies disappear from your computer when you close your web browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. If you have chosen to identify yourself to us then we use session cookies containing encrypted information to allow us to uniquely identify you.

Persistent cookies are used that only we can read and use to identify browsers that have previously visited the Website. When Users provide us with identifiable information about themselves, a unique identifier is assigned to them. This unique identifier is associated with a persistent cookie that we place on the User’s web browser. WD-40 is very careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. 

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website.

To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy. 

WD-40 use the following cookies:

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for, such as remembering your login details or shopping basket items, cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies

These cookies remember choices you make such as the country you visit our Website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Social Media Cookies

These cookies allow you to share what you’ve been doing on the Website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information does not identify individual Users. Log files include internet protocol (“IP”) addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. WD-40 use this information to analyse trends, to administer the Website, to see how Users move around the Website, and to gather demographic information about our User base as a whole. They do not link this automatically-collected data to your personal information. WD-40 collect certain anonymous information from your visit to the Website via industry standard and commercially available web analytics solutions, including Omniture Web Analytics.

Clear Gifs (Web Beacons)

WD-40 use clear gifs (a.k.a. web beacons) that help us better manage content on the Website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the full-stop at the end of this sentence. 

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see section 4 below. 

8. Links to Other Sites

The Website contains links to other websites over which we have no control. We are not responsible for privacy policies or practices of other websites to which you choose to link from this site. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.

9. Your Uploaded Content

You should be aware that if you upload comments, ideas, suggestions, product reviews and/or end user content together with your name or initials to parts of the Website that can be viewed by other Users, or you provide this kind of information directly to us, we will use your comments, ideas, and suggestions, and your name, for our marketing purposes.

If you change your mind and no longer wish your information to be used in this way you should contact us using the contact details at section 13 below.

10. Retention of Information

Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in the future.

Where we process personal information in connection with performing a contract or Service, or for a competition or as otherwise necessary to service you as a customer, we keep the information for five (5) years (unless otherwise required by local law) from your last interaction with us.  

11. Your Rights

You have a right to ask us for a copy of your personal information. You also have the right to ask us to correct, delete or restrict (stop any active) processing of your personal data, and to obtain the personal data you provide to us for a contract or with your consent in a structured, commonly used and machine readable form, and to ask us to share (port) this data to another data controller. 

You have the right to object to the processing of your personal information by us in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). 

These rights may be limited, for example if fulfilling your request would reveal personal data about another person or breach the privacy rights of others, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us using the contact details at section 13 below. If you have unresolved concerns, you have the right to make a complaint to the data protection supervisory authority where you live, work or where you believe a breach may have occurred. 

You do not have to supply us with any personal information in order to visit the Website. If you use our Services we will ask you to supply us with information. When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the services you wish to access and whether the supply of any information we ask for is optional. If you choose not to provide the information, you may not be able to use some Services. 

12. How to Update Your Information

To change or update the information we hold and which relates to you please contact us, using the contact details at section 13. 

13. Contact Information

MAINPPACK LLC is the data controller of your personal information. If you have any questions about this Statement, please contact us at Distributor / Importer / Organization authorized to accept claims in Ukraine: LLC “MAINPACK”, 14021, Ukraine, Chernihiv, st. Shiroka, 2 Phone: +38 0462 677 623.