Last updated: April 22, 2025
Our Commitment
Bath Fitter Distributing Inc. (“Bath Fitter”) is committed to ensuring that persons with disabilities have an equal opportunity to use and benefit from our goods, services and facilities. This includes ensuring that we provide our goods and services to people with disabilities in a manner that respects their dignity and independence. Consistent with our dedication to providing goods and services in accordance with the spirit and intent of the Accessibility for Ontarians with Disabilities Act (“AODA”), this Policy sets out our practices with respect to accessible customer service, design of public spaces and accessible information and communications.
Bath Fitter also has a Multi-Year Accessibility Plan that outlines the steps we have taken to meet out obligations under the AODA.
Definitions
For the purpose of this Policy:
“Disability” means:
• Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
• A condition of mental impairment or a developmental disability;
• A learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• A mental disorder; or
• An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act (Ontario).
“Service animal” means an animal accompanying a person with disabilities if it is readily apparent that the animal is used by the person for reasons relating to their disability, or, if the person provides a letter from a physician or nurse confirming that they require the animal for reasons relating to the disability. This definition includes guide dogs used by the blind or visually impaired.
“Support person” means a person who accompanies a person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods or services. The support person could be a paid personal support worker, a volunteer, a friend or a family member. They do not necessarily need to have special training or qualifications.
CUSTOMER SERVICE
1. Accessible Communication Supports
Bath Fitter and its employees will communicate with people with disabilities in ways that take into account each person’s particular disability.
2. Service Animals and Support Persons
Unless otherwise prohibited by law, persons with disabilities will be permitted to be accompanied by a service animal or support person: (i) where services are provided at premises owned or operated by Bath Fitter; and (ii) where the public or third parties normally have access to such premises.
3. Assistive Devices
Bath Fitter is committed to serving people with disabilities who use assistive devices. Bath Fitter endeavors to become familiar with the various assistive devices used by people with disabilities and will be flexible in facilitating their use by people with disabilities to access our goods and services.
4. Disruption in Service
Bath Fitter will post timely public notice of a current or anticipated disruption in any facilities or services that Bath Fitter provides to enable people with disabilities to access our services. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available.
5. Training
Bath Fitter provides training appropriate to the duties of their employees, volunteers, or other person acting on behalf of Bath Fitter (referred to below as “workers”).
Specifically, workers who may reasonably be expected to interact with the public or third parties on behalf of Bath Fitter, and workers who are involved in the development, approval, monitoring or implementation of Bath Fitter’s customer service policies, practices and procedures about the provision of goods and services to the public and/or third parties, receive training on:
• The purposes of the AODA and the requirements of its Customer Service Standard.
• How to identity, prevent and remove barriers to accessible communication.
• How to provide information through a communication support or accessible format.
• Bath Fitter’s policies, practices and procedures with respect to accessibility and any changes to same.
• The provisions the Ontario Human Rights Code pertaining to disability.
• How to interact and communicate with persons with various types of disability.
• How to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog or other service animal or the assistance of a support person.
• How to use equipment or devices available on Bath Fitter’s premises or otherwise provided by Bath Fitter that may help with the provision of goods or services to a person with a disability.
• What to do if a person with a particular type of disability is having difficulty accessing the provider’s goods or services.
Revised training will be provided in the event of changes to legislation, procedures and/or practices.
Bath Fitter maintains a record of training provided, including the dates on which training was provided and the number of individuals who received it.
DESIGN OF PUBLIC SPACES
In the event that Bath Fitter builds off-street parking facilities or is constructing new service counters, waiting areas, or queuing guides, such space shall be designed and built in accordance with all accessibility requirements of the AODA and applicable building legislation.
INFORMATION AND COMMUNICATION
6. Accessible Formats and Communication Supports
Upon request and where necessary, Bath Fitter will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities in a timely manner, that will take into account the person’s accessibility needs due to the disability. Bath Fitter will consult with the person making the request in determining the suitability of an accessible format or communication support.
7. Web Content
Our internet websites and web content conform with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level AA.
8. Emergency Procedures
In the event that we make public safety information available to the public, we will provide it in an accessible format or with appropriate communication supports as soon as practicable upon request.
9. Feedback Process
Bath Fitter welcomes feedback regarding the methods we use to provide services to persons with disabilities. Customer feedback is encouraged to continue identifying barriers, and to ensure accessibility is always readily available.
Feedback may be provided in person, by telephone, in writing, or by email to:
Spring Letky, from our HR Department at 412-805-6288 or at sletky@bathfitter.com
Bath Fitter will review and assess all feedback and any complaints received with respect to our accessibility practices and policies. Customers can expect to hear back in a timely manner depending on the complexity of the issues raised.
Bath Fitter ensures our feedback process is accessible to people with disabilities through the provision or arrangement of accessible formats and communication supports, upon request.
We may also receive Technical Data about you if you visit other websites employing our cookies. We also have third parties that collect personal information this way, or our vendors, use several common online tracking tools to collect this information.
Controlling Our Tracking Tools
Your browser may give you the ability to control cookies, and browser add-ons like Ghostery allow you to decide which cookies to activate/deactivate. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To control flash cookies, click: http://www.macromedia.com/support/documentation/en/flashplayer/
Why? Because flash cookies cannot be controlled through your browser settings. Your device may not give you the ability to control cookies. If you configure your computer to block cookies, you will limit the functionality we can provide when you visit our Website. If you configure to block or delete cookies, not all of the tracking that we have described in this General Privacy Policy will stop.
Some browsers have a “Do Not Track” feature that lets you inform Website that you do not want to have your online activities tracked. These browser features are not uniform, so we are not currently set up to respond to those signals.
Controlling Online Interest-Based Ads
We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on our Website or device applications. This may also include ads served on other websites. These ads may be based on information collected by us or third parties. For example, information a third party collects when you register on a website: e.g. your zip code. This might be used to target an ad for people in your area. These ads may also be based on your activities on our Website or on third-party websites.
To learn more about interest-based ads and to opt out of certain types of interest-based advertising and certain other uses of information collected over time and across different online services and devices, please contact us at privacy@bathfitter.com. To opt out of certain interest-based advertising associated with your use of device applications, you may be able to adjust your device settings via the applicable settings configuration of your iOS or Android mobile device. Please see the support materials for your operating systems or devices for more information.
Some of the social media platforms we work with may serve you with interest-based advertising on their platforms. In addition to or instead of the opt-out mechanism described above, you may be able to opt out of their interest-based advertising by changing your advertising preferences in the platforms after you log in.
12. Contact Us
If you have additional questions you may call us at 1-800-764-5539 or reach us by email at privacy@bathfitter.com. You can write to us at 225 Roy Street, Saint-Eustache (Quebec) J7R 5R5, Canada.
13. Notice to Residents of Quebec
Not applicable
14. Your California Privacy Rights
Privacy Notice for California Residents According to the CCPA
This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section of the General Privacy Policy.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA’s scope, like:
· health or medical information covered by the
Health Insurance Portability and Accountability Act
of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
· Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Use of Personal Information
Purposes of use or disclosure of your Personal Information are set forth in Section “How We Use Information” of this General Privacy Policy.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose, which may include sharing information about our customers or our visitors with third parties, including, but not limited to Facebook. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, BF Group has disclosed Personal Information for a business purpose. In particular, the following categories of Personal Information collected by BF Group’ have been disclosed for a business purpose:
Sales of Personal Information
In the preceding twelve (12) months, BF Group has not sold any Personal Information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
· The categories of Personal Information we collected about you;
· The categories of sources for Personal Information we collected about you;
· Our business or commercial purpose for collecting or selling that Personal Information;
· The categories of third parties with whom we share that Personal Information;
· The specific pieces of Personal Information we collected about you (also called a “data portability request”);
· If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
· sales, identifying the Personal Information categories that each category of recipient purchased; and
· disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with a legal obligation;
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described in the sections “Access to Specific Information and Data Portability Rights” and “Deletion Request Rights” above, please submit a verifiable consumer request to us at privacy@bathfitter.com, or mail us at 225 Roy Street, Saint-Eustache (Quebec) J7R 5R5, Canada.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative;
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights.
Response Timing and Format
Nevada residents, who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@bathfitter.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements;
The effective date of the notice is indicated at the top of this General Privacy Policy.
16. Privacy Policy According to the GDPR
INTRODUCTION
If processing of your personal information falls within the scope of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (as defined by the GDPR) and on the free movement of such data, known as the General Data Protection Regulation (the “GDPR”), then Bath Fitter Limited, an Irish entity that, with respect of personal information governed by the GDPR serves as a controller. (for the purposes of this GDPR section, “Bath Fitter Ltd.”) shall perform such processing in accordance with GDPR requirements. Therefore, in such case, in addition to the above terms, Bath Fitter Ltd. provides you with the following information:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS GDPR PRIVACY POLICY
This GDPR Privacy Policy that is incorporated into the General Privacy Policy (the “GDPR Privacy Policy”) aims to give you information on how Bath Fitter Ltd. collects and processes personal data that is governed by the GDPR, through your use of its Website, including any data you may provide through the Website when you sign up to our newsletter or marketing emails, or make any enquiry for information from us, or contact us to set up an appointment.
The Website is not intended for children and we do not knowingly collect data relating to children.
CONTROLLER
Bath Fitter Limited, Units 25 & 41 Eastlink Business Park, Ballysimon, Limerick, Ireland
CONTACT DETAILS
If you have any questions about this GDPR Privacy Policy or Bath Fitter Ltd.’s privacy practices with respect to personal information governed by the GDPR, please contact Bath Fitter Ltd. in the following ways:
Email address: privacy@bathfitter.com
Postal address: Units 25 & 41 Eastlink Business Park, Ballysimon, Limerick, Ireland
Telephone: +1 450 472 0027 x6789
You have the right to make a complaint at any time to the appropriate Data Protection Commission. Bath Fitter Ltd. would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact Bath Fitter Ltd. directly in the first instance.
CHANGES TO THE GDPR PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
Bath Fitter Ltd. keeps its GDPR Privacy Policy under regular review.
It is important that the personal data Bath Fitter Ltd. holds about you is accurate and current. Please keep Bath Fitter Ltd. informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Bath Fitter Ltd. does not control these third-party websites and is not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.
2. DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Bath Fitter Ltd. may collect, use, store and transfer different kinds of personal data about you which it has grouped together as follows:
· Identity Data includes name, username or similar identifier, title.
· Contact Data includes location address, email address and telephone numbers.
· Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
· Profile Data includes your interests, preferences, feedback and any survey responses.
· Usage Data includes information about how you use our Website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from Bath Fitter Ltd. and your communication preferences.
Bath Fitter Ltd. also does collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, Bath Fitter Ltd. may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if Bath Fitter Ltd. does combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, Bath Fitter Ltd. does treat the combined data as personal data which will be used in accordance with this GDPR Privacy Policy.
Except for employment-related information, and subject to applicable law, Bath Fitter Ltd. does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Except for employment-related information, and subject to applicable law, Bath Fitter Ltd. does not collect information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where Bath Fitter Ltd. needs to collect personal data by law, or under the terms of a contract it has with you, and you fail to provide that data when requested, Bath Fitter Ltd. may not be able to perform the contract it has or is trying to enter into with you (for example, to provide you with goods or services). In this case, Bath Fitter Ltd. may have to cancel a product or service you have therewith, but Bath Fitter Ltd. will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
Bath Fitter Ltd. uses different methods to collect data from and about you including through:
· Direct interactions. You may give Bath Fitter Ltd. your personal data by filling in forms or by corresponding with Bath Fitter Ltd. by post, phone, email or otherwise. This includes personal data you provide when you:
o contact Bath Fitter Ltd. with an enquiry;
o request marketing to be sent to you or subscribe to any newsletters or other information we make available from time to time;
o enter a promotion or survey;
o talk to any of Bath Fitter Ltd. Employees over the phone or
o give Bath Fitter Ltd. feedback.
· Automated technologies or interactions. As you interact with the Website, Bath Fitter Ltd. will automatically collect Technical Data about your equipment, browsing actions and patterns. Bath Fitter Ltd. does collect this personal data by using cookies, server logs and other similar technologies. Bath Fitter Ltd. may also receive Technical Data about you if you visit other websites employing our cookies. Please, see “Our Tracking Techniques, Cookies, and Way to Control Our Tracking Tools” section of this General Privacy Policy for further details.
Third parties. Bath Fitter Ltd. will receive Technical Data relating to you from Google Analytics.
4. HOW BATH FITTER LTD. USES YOUR PERSONAL DATA
Bath Fitter Ltd. will only use your personal data when the law allows it to. Most commonly, Bath Fitter Ltd. will use your personal data in the following circumstances:
Where Bath Fitter Ltd. needs to perform the contract it is about to enter into or has entered into with you.
Where it is necessary for its legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where Bath Fitter Ltd. needs to comply with a legal obligation.
Generally, Bath Fitter Ltd. does not rely on consent as a legal basis for processing your personal data although it will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting Bath Fitter Ltd.
PURPOSES FOR WHICH BATH FITTER LTD. WILL USE YOUR PERSONAL DATA
Bath Fitter Ltd. has set out below, in a table format, a description of all the ways Bath Fitter Ltd. plans to use your personal data, and which of the legal bases it relies on to do so. Bath Fitter Ltd. has also identified what its legitimate interests are where appropriate.
Note that Bath Fitter Ltd. may process your personal data for more than one lawful ground depending on the specific purpose for which it is using your data. Please contact Bath Fitter Ltd. if you need details about the specific legal basis it is relying on to process your personal data where more than one ground has been set out in the table below.
MARKETING
Bath Fitter Ltd. strives to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you no longer wish to receive marketing information from us, please contact Bath Fitter Ltd. at privacy@bathfitter.com at any time to let it know and it will cease all marketing communications to you.
Note that if you wish to unsubscribe from our email campaigns, please click on the Unsubscribe
link at the bottom of any marketing email sent from us. If you opt out of our email marketing, we
will still send you messages related to our transactions and relationship with you, such as order
confirmations. If you wish to stop receiving text messages from us, reply STOP, QUIT,
CANCEL, OPT-OUT, or UNSUBSCRIBE to any text message sent from us. For more
information, see our Email and Text Communication Terms and Conditions (available at: https://www.bathfitter.com/us-en/privacy-policy/).
PROMOTIONAL OFFERS FROM US
Bath Fitter Ltd. may use your identity, contact, technical, usage and profile data to form a view on what it thinks you may want or need, or what may be of interest to you. This is how Bath Fitter Ltd. decides which products, services and offers may be relevant for you (Bath Fitter Ltd. calls this marketing).
You will receive marketing communications from Bath Fitter Ltd. if you have requested information from Bath Fitter Ltd. or purchased goods or services therefrom and you have not opted out of receiving that marketing, or where you give Bath Fitter Ltd. consent to market to you.
OPTING OUT
You can ask Bath Fitter Ltd. to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you orby contacting Bath Fitter Ltd. at any time at privacy@bathfitter.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to Bath Fitter Ltd. as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
COOKIES
The Cookie Policy applicable to Bath Fitter Ltd. is included in the “Our Tracking Techniques, Cookies, and Way to Control Our Tracking Tools” section of this General Privacy Policy.
CHANGE OF PURPOSE
Bath Fitter Ltd. will only use your personal data for the purposes for which it has collected it, unless Bath Fitter Ltd. reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Bath Fitter Ltd.
If Bath Fitter Ltd. needs to use your personal data for an unrelated purpose, it will notify you and explain the legal basis which allows Bath Fitter Ltd. to do so.
Please note that Bath Fitter Ltd. may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
Bath Fitter Ltd. may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties, to whom Bath Fitter Ltd. may choose to sell, transfer or merge parts of its business or assets. Alternatively, Bath Fitter Ltd may seek to acquire other businesses or merge with them. If a change happens to Bath Fitter Ltd.’s business, then the new owners may use your personal data in the same way as set out in this GDPR Privacy Policy.
Bath Fitter Ltd. requires all third parties to respect the security of your personal data and to treat it in accordance with the law. Bath Fitter Ltd. does not allow its third-party Service Providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with its instructions.
6. INTERNATIONAL TRANSFERS
Bath Fitter Ltd. shares your personal data with BF Affiliates, including Bath Fitter Distributing Inc., incorporated in Canada and located at 225, rue Roy, Saint-Eustache (Québec) Canada J7R 5R5. In case of a data transfer outside the European Economic Area (EEA), such transfer will, where required, take place pursuant to written agreements, which contain provisions (including, but not limited to, European Contractual Clauses) to safeguard your data.
7. DATA SECURITY
Bath Fitter Ltd. has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, Bath Fitter Ltd. limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Bath Fitter Ltd.’s instructions, and they are subject to a duty of confidentiality.
Bath Fitter Ltd. has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where Bath Fitter Ltd. is legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
Bath Fitter Ltd. will only retain your personal data for as long as reasonably necessary to fulfil the purposes it collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Bath Fitter Ltd. may retain your personal data for a longer period in the event of a complaint or if it reasonably believes there is a prospect of litigation in respect to Bath Fitter Ltd.’s relationship with you.
To determine the appropriate retention period for personal data, Bath Fitter Ltd. considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which Bath Fitter Ltd. processes your personal data and whether Bath Fitter Ltd. can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law Bath Fitter Ltd. has to keep basic information about its customers for six years after they cease being customers for certain regulatory purposes.
In some circumstances you can ask Bath Fitter Ltd. to delete your data: see Section 9 of this GDPR portion of this General Privacy Policy “Your Legal Rights” below for further information.
In some circumstances Bath Fitter Ltd. will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case Bath Fitter Ltd. may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the following:
Request access to your personal data. This enables you to receive a copy of the personal data Bath Fitter Ltd. holds about you and to check that Bath Fitter Ltd. is lawfully processing it; Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data Bath Fitter Ltd. holds about you corrected, though Bath Fitter Ltd. may need to verify the accuracy of the new data you provide thereto; Request erasure of your personal data. This enables you to ask Bath Fitter Ltd. to delete or remove personal data where there is no good reason for Bath Fitter Ltd. continuing to process it. You also have the right to ask Bath Fitter Ltd. to delete or remove your personal data where you have successfully exercised your right to object to processing (see section “Object to processing” of this GDPR Privacy Policy below), where Bath Fitter Ltd. may have processed your information unlawfully or where Bath Fitter Ltd. is required to erase your personal data to comply with local law. Note, however, that Bath Fitter Ltd. may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request; Object to processing of your personal data where Bath Fitter Ltd. is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where Bath Fitter Ltd. is processing your personal data for direct marketing purposes. In some cases, Bath Fitter Ltd. may demonstrate that it has a compelling legitimate ground to process your information which override your rights and freedoms; Request restriction of processing of your personal data. This enables you to ask Bath Fitter Ltd. to suspend the processing of your personal data in the following scenarios:
o If you want Bath Fitter Ltd. to establish the data’s accuracy.
o Where you need Bath Fitter Ltd. to hold the data even if it no longer requires it as you need it to establish, exercise or defend legal claims.
You have objected to Bath Fitter Ltd.’s use of your data but Bath Fitter Ltd. needs to verify whether it has an overriding legitimate ground to use it; Request the transfer of your personal data to you or to a third party. Bath Fitter Ltd. will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Bath Fitter Ltd. to use or where Bath Fitter Ltd. used the information to perform a contract with you; and Withdraw consent at any time where Bath Fitter Ltd. is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Bath Fitter Ltd. may not be able to provide certain products or services to you. Bath Fitter Ltd. will advise you if this is the case at the time you withdraw your consent.If you wish to exercise any of the rights set out above, please contact Bath Fitter Ltd.’s data privacy manager.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Bath Fitter Ltd. may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, Bath Fitter Ltd. could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
Bath Fitter Ltd. may need to request specific information from you to help Bath Fitter Ltd. confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person, who has no right to receive it. Bath Fitter Ltd. may also contact you to ask you for further information in relation to your request to speed up its response.
TIME LIMIT TO RESPOND
Bath Fitter Ltd. tries to respond to all legitimate requests within one month. Occasionally it could take Bath Fitter Ltd. longer than a month if your request is particularly complex or you have made a number of requests. In this case, Bath Fitter Ltd. will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of Bath Fitter Ltd.’s business in conducting and managing its business to enable it to give you the best service/product and the best and most secure experience. Bath Fitter Ltd. makes sure it considers and balances any potential impact on you (both positive and negative) and your rights before Bath Fitter Ltd. processes your personal data for its legitimate interests. Bath Fitter Ltd. does not use your personal data for activities where its interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how Bath Fitter Ltd. assesses its legitimate interests against any potential impact on you in respect of specific activities by contacting Bath Fitter Ltd.’s data privacy manager.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request (or in response to an enquiry from you) before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that Bath Fitter Ltd. is subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the BF Group including Bath Fitter Distributing Inc. and who are based in Canada and other countries acting as controllers and processors and who provide IT, system administration, support and maintenance, management, hosting of data, financial and business support services
EXTERNAL THIRD PARTIES
Service providers acting as processors based in the EEA and outside of the EEA who provide business support services, IT, HR, marketing, customer experience and system administration services.
Service providers acting as processors based in the EEA and outside of the EEA who provide surveying, measurements, photographic, design, fabrication, repair and installation services.
Professional advisers acting as processors and controllers including lawyers, marketing agencies, bankers, auditors and insurers based in the EEA and outside of the EEA who provide consultancy, banking, legal, insurance and accounting services.
The Revenue Commissioners, regulators and other authorities acting as controllers based in Ireland who require reporting of processing activities in certain circumstances.
Contractors for after sale/installation services
17. Changes to the General Privacy Policy and the Specific Policies Pertaining to Certain Jurisdictions
From time to time we may change our General Privacy Policy and/or our specific policies pertaining to certain jurisdictions where we do business. We will notify you of any material changes to any of the above policies by posting an updated copy on our Website. Please check our Website periodically for updates.
· General Privacy Policy
o Effective Date: 14/06/2019
o Last Revision Date: 07/11/2022
· Policies Specific to Certain Jurisdictions
o California: Effective Date: 14/06/2019 – Last Revision Date: 07/11/2022
o Nevada: Effective Date: 20/07/2021 – Last Revision Date: 07/11/2022
o Europe: Effective Date: 14/6/2019 – Last Revision Date: 07/11/2022
o Quebec: Effective Date: 22/09/2022 – Last Revision Date: 07/11/2022
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