This policy applies to the www.cloroxpool.com website (the “Website”), the My Pool Care Assistant mobile software application (the “Mobile App”), and the My Pool Care Expert kiosk software application (the “Kiosk App”). The Website, Mobile App, and Kiosk App (collectively, referred to herein as the “Services”) are all operated by Easy 1 2 3 Pool Care LLC, an independent licensee of The Clorox Company, which is sometimes referenced herein as “Company”, “we”, “us” or “our”. We recognize the importance of privacy to you and are committed to protecting your privacy when you use our Services. As a result, we have instituted this privacy policy (“Privacy Policy”) pertaining to our Services. Company is providing this notice to explain how we and our licensees collect, use, disclose and protect the personal and non-personal information that we compile from you in connection with your use of the Services. Please note that this Privacy Policy applies only to the use and collection of data in connection with the Services, and does not apply to any other data collected by us online or offline, or data collected by our third party partners, except as may be specified herein.

In general, you may use the Services and view content made available through the Services while remaining anonymous by not providing any personal information. By using the Services, you agree to their Terms of Use, including this Privacy Policy which is a component thereof. If you provide us with your personal information, you consent to the collection, use and disclosure of your information as described in this Privacy Policy. If you do not agree with this policy, please do not provide us any information and do not use the Services.

For purposes of this Privacy Policy, the definition of Company (and references to “we”, “us” and “our”) may include any of our licensors, licensees, sponsors, vendors, contractors and/or service providers and any of our or their respective direct or indirect parents, subsidiaries or affiliates, officers, directors, shareholders, employees, agents, representatives, successors and/or assigns in their capacity, and as they are retained to assist in the administration of the Services, the collection, cataloging and/or analysis of data, and/or the processing or handling of any visitor transactions. We will comply with applicable law regarding the parties to whom we allow access to user information.

Because The Clorox Company is based in the United States and the Services are intended solely for U.S. residents, you agree that your personal information will be subject to disclosures and uses in accordance with U.S. law as described in this Privacy Policy.

  1. Registering with Company
  2. Information We Collect
  3. Collection of Personally Identifying Information from or about Children
  4. Use and Disclosure of Your Personal Information
  5. Your California Privacy Rights
  6. Links
  7. Security
  8. Access, Correction and Contacting Us
  9. Privacy Policy Changes

1. Registering with Company

In order to use certain features or services provided by our Services, you may need to register with us, which will entail your disclosure and transmission of certain information about you. When you choose to register with us, you are opting to receive communications from us, as described in this Privacy Policy. In connection with your registration, or at any time after registering, you may “opt-out” or unsubscribe from receiving any communications from us by sending an email requesting same to  customercare@cloroxpool.com or through such other means as we may communicate to you.

2. Information We Collect

Personal Information. If you register with us, we shall collect certain personal information provided by you, which may include your name, address, date of birth, telephone number, e-mail address, and certain other personal, professional and demographic information about you. We may also collect this type of information and additional personal information when you subscribe to communications by way of the Services, make changes to your account(s) for the Services, participate in promotions, sweepstakes, or contests, purchase products or services by way of our Services, send us communications, or otherwise interact with the Services. Such additional personal information may include your feedback about our products and services, demographic data, comments about the Services, responses to survey questions, your purchasing and browsing history, and any other information you choose to provide to us. In certain rare situations, we may also require you to provide us your social security or tax identification number in connection with the distribution of promotional prizes and/or awards.

Non-personal Information. We may also collect non-identifiable information that becomes available to us as a result of your use of our Services or from third-parties. Such information does not uniquely identify any individual. This information includes, for example, your IP address (a number automatically assigned to your computer when you visit the Website or use the Mobile App, and which is logged by our servers), your Internet Service Provider (“ISP”), your web browser, the type of operating system, the domain name of the website which links you to our Website or Mobile App, the pages you visited, the average time spent using our Services, and the products searched for by way of our Services. Non-personal information may also include demographics data, including, for example, marital status, income level, household size, age range, and the like. Further, we may collect certain geo-location data from you in connection with your use of the Services’ to, for example, locate sales outlets or distributors for our products and services. We may link such geo-location data to other information that you provide to us or that may be accessed in connection with your use of our Services.

To support the successful dissemination of information through the Services, we will review visitor trends and data recorded on certain log files. If you access the Services through a mobile device, such as a smartphone or tablet, we may also collect information about your mobile device type, its operating system, and its unique device ID. In connection with such log files and data, we may use analysis software to generate reports that will allow us to determine how we can enhance your experience with our Services. This information will not be used to ascertain your identity or the substance of what you are viewing. The log files may be purged periodically, in our discretion, to maximize space on a server.

We may, from time to time, use cookies, web beacons, clear GIF, pixel or other internet technologies in connection with our Services, which may uniquely identify your account or the IP address associated with your internet device. Cookies are small text files that are placed on your hard drive to recognize you as a repeat user of our Services, track your use of our Services and target advertising. This allows for personalization of certain aspects of your use of our Services. Information gathered from such technologies in this way is only used on an aggregate basis. Unless a visitor specifically consents to retention of personal information or provides their identity to us, e.g., by registering an account with our Services, providing information through an online form or sending us correspondence by way of the Services, we will not know the identification of individual visitors. We may use cookies to store preferences; record session information; develop information about preferences and interests of users of our Services; record past activity at a website in order to provide better service when you return to our Services; or customize web page content based on information you voluntarily provide.

You may be able to disable “persistent” cookies using your internet browser settings. Please consult your browser’s help function for information on how to disable cookies. Note that if you disable cookies, certain features of our Services may not function properly. Otherwise, “session” cookies are automatically deleted once you close your web browser.

Company, whether directly or through certain third-party service providers, may use certain other types of cookies to collect data about your use of our Services, as well as about your use of other third-party websites and resources, to serve customized advertisements to you. These service providers may participate in the Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance, and, if so, our targeted advertisements may be delivered with “AdChoices” icons that help you understand how data about you is being used and provide you with the ability to opt out of such behaviorally targeted advertising. Additionally, offerings in our Services may also contain such icons. If you click an AdChoices icon, you will be provided with a list of third parties collecting behavioral advertising data through our Services, such as BazaarVoice. You should visit the privacy policies of those service providers to learn more about how they collect and use data and how you may opt out of such collection and use, if applicable. To learn more about the Self-Regulatory Program for Online Behavioral Advertising, please visit http://www.aboutads.info/consumers. From a smartphone or other mobile device, you may also access the Digital Advertising Alliance’s “AppChoices” website to download a mobile app that allows you to set preferences for data collection and use across your mobile apps. Please note that Company does not endorse or warrant any of the products, services or information available at that site.

You may be able to opt-out of receiving focused advertisements from third party advertisers and advertising networks who are members of the Network Advertising Initiative (NAI) through its website. Further, please note that although your browser may have a “do not track” feature, the Web Site may not function properly with such feature and such feature may not successfully prevent the gathering of information as specified herein.

Flash LSOs. Company may also utilize Flash Local Storage Objects (“Flash LSOs”) to recall who you are and your preferences for the Website in connection with your past visits. The amount and type of data stored in Flash LSOs are different from cookies. Flash LSOs cannot typically be controlled, deleted, or disabled. You, however, may learn more about these objects by referring to the instructions and help materials available to you in your Flash player, and you may choose to delete such Flash LSOs through those tools.

Third Party Applications and Interfaces. The Services’ content and features may be made available through certain third party application programming interfaces (“API”), extensions, embedded script, or other gadgets available through our Services, from third party sites, or from certain social media platforms. Interacting with and allowing or accepting such third party technologies may authorize these third parties to obtain your information and/or share your information with us or others, based on each such third party’s terms of use and any permissions you have granted to each such third party. Any personal or non-personal information that we receive through such third party technologies will be used and maintained in accordance with this Privacy Policy.

Combined Information. We may, from time to time, combine certain non-personal and personal information to improve your experience with the Services and the Services’ offerings. The non-personal information may be information we have obtained from you (such as your IP address) or from a third-party (such as from mobile advertisements). Any such combined information will be regarded as personal information and maintained accordingly.

3. Collection of Personally Identifying Information from or about Children

Company does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to Company. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at  customercare@cloroxpool.com.

4. Use and Disclosure of Your Personal Information

The information we learn from visitors and users of our Services helps us personalize and improve the Services and products and services that we describe or make available through our Services. We use your information, including your contact information, as described elsewhere in this Privacy Policy, to respond to your requests for information and to generate and maintain mailing lists, including for marketing purposes. We may also use your personal information for the following purposes:

  • establishment and maintenance of our relationship with you;
  • responding to your requests and inquiries;
  • registering you for programs, events and/or services that you have requested;
  • process, fulfill and follow-up on your orders;
  • providing you with any prize or award that may be due to you;
  • conduct analysis and research regarding our products, services, and the Services;
  • for social media communication and networking purposes;
  • allow your feedback, comments, and contributions to appear on the Website or in the Mobile App or Kiosk App;
  • meeting legal, regulatory, insurance, security and processing requirements; and
  • otherwise with your consent.

We do not sell or rent your personal information to third parties without your permission, except that we may share your personal information with our affiliates, retail partners and other third party business partners (and their service providers), in certain circumstances, such as:

  • for research and analysis purposes;
  • to inform such parties to cease the transmission of communications on our behalf to those users of the Services who have opted out of such communications; and
  • if you have opted-in to receive promotional communications from us, to send customized communications to you jointly offering a product or service.

We do not authorize these third parties to use your personal information for any direct marketing, in accordance with the California “Shine the Light” law, California Civil Code § 1798.83, unless we have explicitly given you the option to opt-in or opt out of such disclosure. We require these parties to maintain the confidentiality of any of your personal information obtained through our Services.

We may, as necessary, provide your personal information to certain third party service providers to conduct certain actions on our behalf, such as customer service, technical support, order fulfillment, sweepstakes and promotions administration, loyalty and rebate program management, product delivery, e-commerce services, payment processing, and the like. These third parties are not permitted to use your data for purposes other than for which it has been provided. Further, we do not authorize these third parties to disclose your personal information to unauthorized parties or use that information for any direct marketing purposes.

The Services may contain certain interactive features and functionality, such as forums, bulletin boards, product reviews, social media tools, and the like. When you participate in such features, your username and any other personal information you choose to display in any publicly available offerings of the Services, such as Website pages, may be seen by others, and you should exercise caution when disclosing such information and realize that information your post could remain viewable in cached or archived webpages or copied and stored by other users even after you delete it. We cannot control the actions of other users of our Services, and we are not responsible for the results of your postings. Furthermore, when you participate in these interactive features, you may be agreeing to terms of use that, among other things, allow us to use your name and other information in our marketing and advertising. Please refer to our Terms of Use for more information.

In addition, we may share your personally identifying information with any third-party, without your consent or approval and without notice to you, (i) as permitted or required by law, (ii) as incidental to a corporate sale, merger, reorganization, dissolution, bankruptcy or similar event, (iii) under circumstances we believe reasonably necessary to protect the personal safety of our employees, users of the Services, or the public, (iv) to disclose information that is necessary to identify, contact or bring legal action against someone who may be violating our published policies, or (v) as is otherwise described in this Privacy Policy.

5. Your California Privacy Rights

California residents may have the right to request and receive certain information about a company’s disclosure of such residents’ personal information to third parties for their own direct marketing use, and such residents’ choices with respect to such disclosures. Company does not share your personal information with third parties for their own direct marketing use unless you are first given the opportunity to opt in or out. As such, we are exempt from this requirement. For further information or questions, please contact us at the address listed below.

6. Links

Our Services may contain links to other websites or resources. Per our Terms of Use, please recognize that we do not control these third party websites and resources, and this Privacy Policy will not apply to those websites and resources. You should consult each applicable privacy policy before using another linked website or resource.

In particular, we may allow you to select products for purchase and then purchase such products through a third-party e-commerce web site or mobile app. In such circumstances, you will be directed or forwarded to a web site or mobile app hosted by a third party (or its authorized service provider). Any personal information about you that is collected by such third party or that you may provide to such third party is subject to that party’s privacy policy and terms of use, and not this Privacy Policy or our Terms of Use.

7. Security

While we will employ reasonable precautions, subject to our judgment, to protect against the loss, misuse, and alteration of the information under our control, we cannot guarantee that our security measures will prevent third-parties from intercepting information from our network and systems. You should not assume or expect that any communication that you transmit to us (such as personally identifiable or other data, questions or answers, comments, or suggestions) is confidential. Company shall not be liable or responsible if any information about you is intercepted and used by an unintended recipient. If you have reason to believe that your confidential account or other information provided in relation to our Services is no longer secure, please contact us at customercare@cloroxpool.com as soon as possible.

8. Access, Correction and Contacting Us

If you have questions about anything contained in this Privacy Policy, including how your personal information is used or if you wish to request that we correct, change or remove any information about you that we may have collected, you may contact us at customercare@cloroxpool.com. Further, we will maintain your personal information as long as necessary pursuant to this Privacy Policy and as we deem necessary in our discretion, unless a longer retention period is required or allowed by law. If you have an account with our Services and would like to update the personal information you have provided to us, you may also be able to view and make changes or corrections to your personal information through certain features of the Services.

If you no longer want to receive promotional or marketing communications from us, you may unsubscribe from or opt out of such communications by notifying us at customercare@cloroxpool.com, or through such other opt-out measures as we may provide in our communications to you. Additionally, any subscribed-to promotional text messages from us will have instructions for unsubscribing from such messages. If you have any issues or concerns with regard to opting out of communications from us, please contact us using the contact information set forth above. We may require a reasonable period of time to meet your requests and you may continue to receive certain order communications even after opting out, while we are working to address your opt-out request. Further, if you have participated in a promotion with us involving a third party and have subscribed to communications from such third party, you will need to review the privacy policy of such third party or contact such third party to opt out of future communications from it.

9. Privacy Policy Changes

This Privacy Policy may be revised from time to time by us in our sole discretion. Any changes will be effective upon posting of the revisions on the Website or in the Mobile App or Kiosk App. We may post changes or modifications to referenced policies and guidelines without your approval, and may determine whether and when any such changes apply to you. Your use of the Services following our posting of any changes will constitute your acceptance of such changes. Should you not wish to be bound by the modified Privacy Policy, please do not use the Services.