Privacy Policy

Zurn Elkay Water Solutions Corporation, 511 W Freshwater Way, Milwaukee, WI 53204, USA; email: dataprivacy@zurn.com ("Zurn Elkay,” “We/us,” or “Company") and each of its affiliates and subsidiaries (collectively the "Zurn Group") take data privacy seriously. This Zurn Data Privacy Policy (“Privacy Policy”) informs our business partners (including customers, vendors and suppliers), job applicants and website users how we as controllers / responsible entities for data processing collect and process personal data and provides other information to data subjects. This Privacy Policy applies to all individuals who access this website (“Site”) and any of our online, and where applicable, offline services (collectively, “Services”).

For information about the cookies we use, how we use them, and the options you have to accept or decline certain cookies, please visit our Cookie Policy available here or by clicking on the “Cookie Settings” button at the bottom of participating Zurn Elkay Websites, This Privacy Policy includes the following sections:

1. Definitions
2. Controller
3. Categories of Personal Data, Processing Purposes, and Sources of Personal Data
4. Categories of Recipients and International Transfers
5. Retention Period
6. Opt-Out Preference Signals
7. Security
8. Third-Party Links
9. Children’s Privacy
10. Notice to California Residents
11. Your Privacy Rights
12. Questions and Contact Information
13. Changes to the Privacy Policy

1. Definitions:

As this Privacy Policy shall cover the transparency and information obligations stemming from various national and state data protection laws as applicable to the Zurn Group, the terms and terminology used within this Privacy Policy shall be interpreted in light of the respective terminology used and defined by the applicable data protection law. For example:

2. Controller: Who is the Controller for your Personal Data

The responsible controller within the Zurn Group will depend on the processing activities that apply to you. For example,

• If you are a website user and visit a webpage of the Zurn Group (a “Website” or “Zurn Elkay Website”), the Controller is the affiliate of the Zurn Group identified on the webpage.
• If you are a customer, vendor, supplier or business partner and you interact with an affiliate of the Zurn Group for business reasons, the Controller is the affiliate of the Zurn Group with whom you interact.
• If you are a job applicant and you submitted your application, the affiliate of the Zurn Group who offers the job to which you apply is the Controller.

In the following, the term “Controller”, “we”, “us” or “our” refers to the affiliate of the Zurn Group that acts as the controller for the particular processing activities as explained above. If you have any questions as to who the Controller of your personal data is, please contact us via the contact details set out in section 12.

3. Categories of Personal Data, Processing Purposes and Sources of Personal Data: What personal data do we process about you, why and from where?

Depending on how you interact with us, we may process the following categories of personal data for the identified processing purposes:

3.1 Website Metadata

We will collect only the following metadata resulting from your usage of our Zurn Elkay Websites: browser type and version, operating system and interface, website from which you are visiting (referrer URL), webpage(s) you visit on our Zurn Elkay Websites and activity on those Zurn Elkay Websites, date and time of Zurn Elkay Websites’ access, device identifier or MAC address and internet protocol (IP) address. This personal data includes Internet or other Electronic Network Activity Information under the CCPA. Further personal data may be collected through cookies, as provided in our Cookie Policy linked at the bottom of our Websites.

The metadata will be used to enable your access to our Zurn Elkay Websites and to improve our services as well as the quality of our Zurn Elkay Websites. We will analyze user behavior in anonymized form to prevent fraud and misuse of our IT systems, as well as to ensure physical, IT, and network security.

3.2 Contact Details

If you contact us through a portal on a Zurn Elkay Website, you will be asked to provide the following personal data: name, company, title, address, email address, telephone number, and fax number. We process such personal data to answer your queries or information requests. This personal data includes Identifiers under the CCPA.

3.3 Newsletter and Product Catalogues

If you request our newsletter or product catalogues, we may collect and process the following personal data: name, title, company name, email address, postal address (if requesting postal mails), and your voluntary request to receive marketing communications. This personal data includes Identifiers under the CCPA. We process such personal data to provide you with the requested communications, as well as to analyze your interests for marketing purposes, to distribute additional marketing materials and to analyze the success of our marketing activities, customer segmentation and customer profiling, lead generation to the extent permitted by applicable law.

3.4 Portal Users

If you request access to an online portal we operate, in addition to the information described in Section 3.1 of this policy, we may collect and process the following personal data: name, title, company name, email address, portal access username, portal access password and your voluntary request to receive access to such portal. This personal data includes Identifiers under the CCPA. We process such personal data to facilitate your access to the portal, to protect the security of our systems and infrastructure, to meet regulatory and legal obligations, to establish or defend legal claims, and to meet contractual obligations. We may also use such information to analyze your interests for marketing purposes, to distribute additional marketing materials and to analyze the success of our marketing activities, customer segmentation, customer profiling, lead generation, to the extent permitted by applicable law.

3.5 plumbSMART™ and inSpec users

To the extent provided to us, we collect and process the following personal data of plumbSMART ™ and inSpec users: name, email address, company postal address. This personal data includes Identifiers under the CCPA. We process this information to facilitate the connected device operation and meet our contractual obligations.

3.6 Business Partners

To the extent provided to us, we collect and process the following personal data of current and potential business partner contacts: name, title, function, company name, company email address, company postal address, and any voluntary requests for communications from us. This personal data includes Identifiers under the CCPA. We process this information to facilitate business partner engagements, to protect the security of our systems and infrastructure, to meet regulatory and legal obligations, to establish and defend legal claims, and to meet contractual obligations.

3.7 Visitors to Our Premises

To the extent provided to us, we collect and process the following personal data of visitors to our premises: name, title, company name, function, company email address, company postal address, identity of visitor's Zurn Elkay contact, date and duration of visit, vehicle information. In the case of a government-identified health emergency, we may collect information necessary to facilitate in-person visits in accordance with government and/or health regulator direction or advice, including, with visitor consent where necessary, temperature and only in accordance with applicable law. This pandemic-related collection of personal data would include Identifiers and Health Information under the CCPA. Our premises may also be subject to CCTV, biometric or other security solutions that may capture images and/or audio of visitors, in accordance with applicable law. We process this information to facilitate such in-person visits, to protect our company, employees and visitors, to meet regulatory and legal obligations, to establish and defend legal claims, and to meet contractual obligations.

The Company does not sell or share “sensitive personal information” as defined by the CCPA.

4. Categories of Recipients and International Transfers: Who do we transfer your personal data to and where are they located?

In the preceding twelve (12) months, we have transferred and disclosed, and we further may transfer, your personal data to third parties for the processing purposes described above as follows. The personal data transferred may include Identifiers, Internet or other Electronic Network Activity Information, Health Information, Characteristics of Protected Classifications, Education Information and Professional and Employment-related Information and Sensitive Information:

• Within the Zurn Group: Affiliates within the Zurn Group may receive your personal data as necessary for the processing purposes described above. Depending on the categories of personal data and the purposes for which the personal data has been collected, different internal departments within the Zurn Group may receive your personal data. For example, our IT department may have access to your account data. Moreover, other departments within the Zurn Group have access to certain personal data about you on a need-to-know basis, such as the legal department, the finance department, or internal auditing. Depending on their processing activities, such affiliates may act as processors or as controllers.

The affiliates of the Zurn Group processing data are identified in Annex 1.

• To service providers / processors: Certain service providers (for a business purpose), whether affiliated or unaffiliated, may receive your personal data to process such data under appropriate instructions as necessary for the processing purposes described above as processors. Such service providers may include website service providers, marketing service providers, IT support service providers, cloud service providers, distributors, vendors and other service providers who support us in carrying out our business activities and maintaining our commercial relationship with you. Such service providers will act on our behalf and will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard your personal data and to process your personal data only as instructed.

You can ask for further details of currently engaged service providers by contacting us as set out in Section 12 below.

• Other recipients: In compliance with applicable data protection law, we may transfer personal data to local or foreign law enforcement agencies, governmental authorities, judicial authorities, legal counsel, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties involved in the merger or acquisition.

Any access to your personal data is restricted to individuals with a need-to-know and only if required to fulfill their job responsibilities.

We operate internationally and transfer information to the United States for the purposes described in this policy. The United States may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. Your personal data can be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.

For any transfers of personal data from the European Economic Area (EEA), Switzerland or the United Kingdom that we make to other entities as described in this Privacy Policy, we use appropriate safeguards to ensure for the lawful processing and transfer of the personal data, including, when appropriate, the use of standard contractual clauses approved by the European Commission. To obtain a copy of the safeguards, contact us as set forth in section 12.

5. Retention Period: How long do we keep your personal data?

Your personal data will be retained as long as necessary to provide you with the services and products requested. Your metadata will be deleted 26 months after your visit to the Zurn Elkay Website, except as otherwise described in our Cookie Policy linked at the bottom of our Websites. Your newsletter registration data will be deleted after you inform us that you no longer want to receive marketing information from us. Your job applicant data will be deleted within the local statutory retention periods. If you are a customer or vendor contact, your data will be kept as long as we consider your company a customer of our products. In case of a deletion request, we may be required to delete all or certain of your personal data sooner. 

If we are required by applicable law to retain your personal data, we will not delete them. We may also retain your personal data if we need your personal data to establish, exercise, or defend a legal claim, only on a need-to-know basis. To the extent possible and commercially and technically practicable, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship.

6. Opt-Out Preference Signals

The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

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, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

7. Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

8. Third-Party Links

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

9. Children's Privacy

The Site and Services are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal data from children under 16.

10. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

This California Privacy Notice does not apply to employment-related personal information collected from our California-based employees, job applicants, independent contractors, or similar individuals. If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please contact us at the “Contact Information” below or your local human resources department if you would like additional information about how we process your personal information.

10.1 Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Effective Date and Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers, such as name, alias, postal address, online identifier, Internet Protocol address, email address, account name)
• Unique personal identifiers, such as device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device
• Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)), such as signature, telephone number, bank account number, credit card number, debit card number, as well as the categories listed in “Identifiers” category above
• Commercial information, such as records of products or services purchased or considered; other purchasing or consuming histories or tendencies
• Biometric information, such as imagery of face, keystroke patterns or rhythms
• Internet or other electronic network activity information, such as browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information

We collect Personal Information directly from California residents and from advertising networks, internet service providers, data analytics providers, operating systems and platforms, and social networks. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “Categories of Personal Data, Purposes for Processing and Sources of Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
• Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or product that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
• Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

10.2 Sale, Sharing, and Disclosure of Personal Information

The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or sharing of Personal Information under California law. This may include showing you advertisements on other websites.

The following table identifies the categories of Personal Information that we sold to or shared with third parties in the 12 months preceding the Effective and Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

We may sell or share (and may have sold or shared during the preceding 12 months), the following categories of personal information about you to third-party online adverting services, social networks, and internet cookie recipients:

• Identifiers
• Internet or Network Activity information
• Geolocation data

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective and Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.

We disclosed Personal Information to third parties for the business or commercial purposes identified in Section 10.1 above. 

We do not knowingly collect or sell or share the Personal Information of consumers under 16 years of age. We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about individuals and, consequently, do not collect sensitive Personal Information or use it for purposes other than those allowed by the CCPA and its regulations.

10.3 Your California Privacy Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;

The right to delete Personal Information that we collected from you, subject to certain exceptions; The right to correct inaccurate Personal Information that we maintain about you;

If we sell or share Personal Information, the right to opt out of the sale or sharing;

If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and 

The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Exercise the Above Rights

If you would like to submit a request on behalf of yourself or another California resident, you may submit a request to know, delete, and/or correct by any of the means provided in Section 12 of this Privacy Policy. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

10.6 Shine the Light Law

We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

10.7 Your Privacy Rights: What rights do you have and how can you assert your rights?

Right to withdraw your consent: If you have declared your consent regarding certain collecting, processing, and use of your personal data (in particular, regarding the receipt of direct marketing communication via email, SMS/WhatsApp, and telephone), you can withdraw this consent at any time. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can withdraw your consent as follows: send an email request to dataprivacy@zurn.com. Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with basic tariffs.

Additional data privacy rights: Pursuant to applicable data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; and/or (vi) object to the processing of your personal data (including objection to direct marketing and profiling). Please note that these aforementioned rights might be limited under the applicable local data protection law.

Contact details to exercise your data privacy rights: To exercise your rights, please contact us as stated under Section 12 below.

12. Questions and Contact Information

If you have any questions about this Privacy Policy, please contact us at Zurn Elkay Water Solutions Corporation, 511 W. Freshwater Way, Milwaukee, WI 53204, USA.

If you would like to submit a data-subject request and/or otherwise exercise your rights under applicable data-protection laws, please or by submit a request form available here; send an email to dataprivacy@zurn.com; or call us, toll free, at 877.888.4807. Please include the following information with your request, as it will be necessary to verify your identity and appropriately respond to your request.

1. First Name:
2. Last Name:
3. Address (optional):
4. E-mail Address:
5. Your country and state of residency:
6. Please indicate your relationship with Zurn Elkay:
   1. Customer
   2. Vendor
   3. Consumer
   4. Employee
   5. Former employee
   6. Other (identify)
7. Identify the Nature of Your Request and Details of Request
   1. Request to know categories of personal information Zurn Elkay has collected, used, disclosed and/or sold about the consumer.
   2. Request to obtain specific pieces of personal information Zurn Elkay has collected about the consumer.
   3. Request to delete personal information Zurn Elkay has collected about the consumer.
   4. Request to correct personal information Zurn Elkay has collected about the consumer.
   5. Request to opt out of the ‘sale’ or ‘sharing’ of personal information about the consumer.

The information we request from you above is strictly for the purpose of enabling us to verify and respond to your request and will be processed in accordance with applicable data protection laws. By submitting this information, you hereby certify that the information submitted is complete, accurate and up-to-date, and that you are the consumer who is the subject of the request or have been authorized by that consumer to act on his/her behalf, as indicated above. You understand that it may be necessary for Zurn Elkay to verify the identity of the consumer and/or authorized agent for this request and additional information may be requested for this purpose.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any such changes, including when they will take effect, by updating the Effective and Last Updated Date at the top of this page or as otherwise required by applicable law.

Annex I

Zurn Group Companies