At StenTech, we believe trust is the cornerstone of all relationships

StenTech values your privacy. This notice describes the personal information StenTech may collect about you:

• through websites operated by us, from which you are accessing this Privacy Notice (the “Websites”),
• through the software applications made available by us for use on or through computers and mobile devices (the “Apps”),
• through any of our Internet of Things connected or connectable devices (our “IoT Devices”), including our internet-connected water solution products,
• through our social media pages and apps that we control from which you are accessing this Privacy Notice (collectively, our “Social Media Pages”),
• through HTML-formatted email messages that we send to you that link to this Privacy Notice, and
• through other online and offline interactions you have with us, such as web-based trainings or in-person events.

Collectively, we refer to the Websites, Apps, IoT Devices, Social Media Pages, emails and other online and offline activities as the “Services.”

For the purposes of this notice, “StenTech” refers to StenTech plc and any of its subsidiaries who link to or otherwise provide you with this Privacy Notice. Please note that some of our subsidiaries may post separate privacy notices on their websites, and they are subject to their own posted privacy notices rather than this Privacy Notice.

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. When StenTech collects your personal information, we seek to collect what is relevant, adequate, and not excessive for the purpose it is collected.

• The ways that we may collect information about you include the following:
• We may collect personal information from a variety of sources, such as the telephone, our sites, online video calls, our online or mobile applications or services, our transfer agent or our online advertisements.
• Through the Services: For example, we may collect personal information during the initiation or execution of business relationships, during events, trainings or tradeshows, when you subscribe to newsletters or request publications, create an account, return or exchange a product, activate a gift card, complete surveys, register for StenTech events or online services, contact us for further information, install and use our IoT Devices or Apps, or visit our sites while or before logged into a social media platform.
• From other sources: We may also collect personal information from public sources or third party data providers. For example, our HR team may utilize LinkedIn or other social media platforms to identify employment candidates. Each social media platform has their own policy on the way they process your personal information when you access their sites. If you have any concerns or questions about their use of your personal information, you should read their privacy policies carefully before using them. We may also work with joint marketing partners to identify potential customers, with transfer agents to coordinate interaction with our shareholders or with other third parties to provide services to StenTech employees.
• The types of personal information that we may collect about you include:
• Contact information, such as name, title, phone number, mailing address, and e-mail address;
• Communication information submitted by you, such as orders, questions, photos/videos, and feedback
• Demographic information, such as language, age, and gender;
• Marketing preferences, such as e-mail subscription and frequency preferences;
• Payment data, such as credit card details and account information.
• Device Data,” as defined in our mobile app Terms of Service, when you install and use our IoT Devices or Apps;
• For example, our Apps may include features that allow you to connect the App to on-site cameras that you have installed at your pool build site, to enable you to view photographs or video content that you capture through those cameras (such as live-streaming or time-lapse video) through the App.
• User credentials, when you register to use the Services.

We need to collect personal information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

• We need to collect personal information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
• The length of time you have an active account or relationship with StenTech;
• When we are getting to know you as a potential customer or business partner;
• When we need to comply with a court order, law or legal process;
• When legal requirements and professional guidelines require it – such as tax and audit purposes, information on aspects of health and safety, or in regard to applicable statutes of limitations, litigation or regulatory investigations.

StenTech may use your personal information to serve you, improve our services, and fulfill the purpose for which you gave us your personal information, and for other legitimate business purposes, including to:

• Provide the functionality of the Services and fulfill your requests.
• Carry out transactions you have requested, such as processing orders, registering purchased products, handling warranty claims, and providing related customer service;
• Communicate with you about your account and your purchased products, respond to your inquiries and fulfill your requests;
• Send administrative information to you, such as changes to our terms, conditions and policies;
• Service your purchased products and send information that you request regarding your products’ functionality.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Provide you with information and/or other marketing materials.
• Inform you of products or services available from StenTech in which you may be interested;
• Send you surveys regarding your use of StenTech products and services;
• Facilitate social sharing functionality that you choose to use. For example, our Services include social media features, such as the Facebook "Like" button and widgets, the "share this" widget, or interactive mini-programs that run on our Services.

We will engage in these activities with your consent or where we have a legitimate interest.

• Analyze personal information for business reporting and providing personalized services.
• Analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services;
• Better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
• Better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

• Accomplish our business purposes.
• Run our business operations and manage our risks, including protecting the rights and property of StenTech and others;
• Comply with legal requirements and internal policies, such as audit and security policies;
• Develop new products or services;
• Improve, enhance or modify our products and services, including our events and trainings;
• Identify usage trends, for example, understanding which parts of our Services are of most interest to users;
• Determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

• Allow you to participate in sweepstakes, contests or other promotions.
• We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
• Some of these promotions have additional rules containing information about how we will use and disclose your personal information.

We use this information to manage our contractual relationship with you.

• Aggregate and/or anonymize personal information.
• We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

StenTech may share your personal information with other StenTech entities, brands, divisions, and subsidiaries to serve you, including for the activities listed in this Privacy Notice, and we also may share your personal information with selected third parties as described below.

We share personal information:

• With our affiliated entities for the purposes described in this Privacy Notice. You can consult the list and location of our affiliated entities here. StenTech plc is the party responsible for the management of the jointly-used personal information.
• With trusted third party service providers that carry out activities at our direction. These activities could include any of the activities that StenTech carries out as described in the above section, ‘HOW WE USE YOUR PERSONAL INFORMATION.’ For example, these activities can include website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.
• With third parties, to permit them to send you marketing communications, consistent with your choices.
• With a third-party business partner if you accept an offer from that specific business partner that is made available through our Services;
• With trusted dealers, when you configure the App to share information related to your IoT Device (including Device Data) with a specific dealer. The dealer may use this information to monitor and service your IoT Device and offer you related products and services. You can choose to discontinue the sharing of this information with the dealer on a going-forward basis at any time through the App settings. This will not affect the dealer’s continued retention and use of the information received before you discontinued such sharing.
• With other individuals you designate through an App as shared users of your IoT Device; such shared users will have access to information stored on the App and will be able to monitor and control your IoT Device via the App.
• By using the Services, you may elect to disclose personal information when you post information and content on message boards, chat, profile pages, and blogs (including, without limitation, our Social Media Pages) and when you participate in trainings, workshops and other events. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
• When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
• To third-party sponsors of sweepstakes, contests, and similar promotions.

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations, which can include laws outside your country of residence.
• To cooperate with public and government authorities, such as to respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
• To cooperate with law enforcement, for example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons, including to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

• Browser and device information
• App usage data
• Information collected through IoT Devices, such as data about installation, product configuration, settings, usage, geo-location, and operational data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

If we are required to treat Other Information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this Notice.

Collection of Other Information

We may collect Other Information in a variety of ways, including:

• Through your browser or device: 
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
• Through your use of an App: 
  • When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Using cookies: 
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads.
  • We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Using pixel tags and other similar technologies: 
  • Pixel tags. (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. 
  • Analytics. We use Google Analytics and Adobe Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  These services may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.  You can exercise the opt-out provided by Adobe by visiting: https://www.adobe.com/privacy/opt-out.html.
• Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: 
  • We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
• IP Address: 
  • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
• Physical location:
  • We may collect the physical location of your IoT Device through the location of the mobile phone used by one of our trusted dealers to install the product, if you manually input the device’s physical location in the App, or if you consent to using the map features in the App.
    
  • We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals.  We may use your device’s physical location to provide you with personalized location-based services for your IoT Devices.  We and our service providers may also use your device’s physical location, combined with information about what advertisements you viewed and other information we collect, to provide you with more personalized content and to study the effectiveness of our advertising campaigns.  In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our business and marketing partners may not be able to provide you with the applicable personalized services and content.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with personal information. If we do, we will treat the combined information as personal information as long as it is combined. 

The security of your information is important to us. StenTech has put in place technical and organizational safeguards to protect the confidentiality, integrity, and availability of your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.