SPECIALTY PRODUCTS & INSULATION CO.

PRIVACY POLICY

Last updated: December, 13, 2024

This Privacy Policy describes the policies and procedures of SPI LLC (“SPI”) and our related bodies corporate (together, “SPI”, the “Company”, “we”, “our” or “us”) on the collection, use and disclosure of your information through your interactions with us and on https://www.spi-co.com (the “Site”). We receive information about you from various sources, including: (i) your use of the Site generally, (ii) from third party websites and Site, and (iii) your interactions with us. When you interact with us or use the Site, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

What Happens When There Are Changes to this Privacy Policy?

What If I Have Questions or Concerns?

What Information Do We Collect?

How, and With Whom, Is My Information Shared?

Is Information About Me Secure?

What Information of Mine Can I Access?

What Choices Do I Have Regarding My Information?

Additional Privacy Rights and Data Protection Practices

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you interact with us (regardless of how you interact with us) and when you are using or accessing the Site. This Privacy Policy also covers our treatment of any Personal Information that is shared with us.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to, any third party websites, Site and applications (“Third Party Site”) that you elect to access through the Service or to individuals that we do not manage or employ. We encourage you to carefully review the privacy policies of any Third Party Site you access.

WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Site or sending you an email. When we make changes, we will revise the "last updated" date at the top of the policy. We encourage you to review this Privacy Policy whenever you interact with us, including when you visit the Site. Unless applicable law requires your affirmative consent, a user is bound by any changes to the Privacy Policy when he, she, or they interact with us or use the Site after such changes have been first posted. If applicable law requires your affirmative consent, we will require such affirmative consent the next time you interact with us or access the Site.

WHAT IF I HAVE QUESTIONS OR CONCERNS?

If you have any questions or concerns regarding privacy, please send us a detailed message to [email protected]. We will make every effort to resolve your concerns.

WHAT INFORMATION DO WE COLLECT AND HOW AND WHY DO WE COLLECT THIS INFORMATION?

The information we gather (usually directly from you through your interactions with us) enables us to supply products and services to you, respond to your questions or suggestions, improve the quality of our products or services, conduct marketing activities, detect, prevent, or otherwise address fraud, security or technical issues, respond to user support requests, payment information and personalize, improve and continue to operate the Site. In connection with certain aspects of the Site, we may request, collect and/or display some of your Personal Information. All Personal Information that we require and/or automatically collect are used to fulfill our contractual obligations and/or communicate with our users. To the extent that any Personal Information we request is optional, we will identify this information and you will be informed that the information is optional. You will have to affirmatively provide this optional Personal Information and may always opt-out and stop providing it at any time. We collect the following types of information from you:

Contact Information:

If you wish to contact us, either through the Site or otherwise, or create an account with us, you will generally have to provide information that could be Personal Information, such as your email address, name, and phone number. You acknowledge that this information may be personal to you, and by providing such Personal Information to us, you allow others, including us, to identify you and therefore you may not be anonymous. We may use your contact information to send you information about our products, services and Site when we feel such information is important.

Where we use your Personal Information for marketing purposes, you may opt out of receiving marketing information by notifying us accordingly, or by using any unsubscribe facility we provide for that purpose.

Financial Information:

We do not collect or store any user financial information through the Site, such as your payment method. However, we will collect and process your financial information in relation to each individual purchase order you submit with us. We also use Bill trust for payment processing.     

IP Address Information and Other Information Collected Automatically:

We automatically receive and record information from your web browser when you interact with the Site, including your IP address and geolocation. Your IP address is a number that is automatically assigned to your computer by your internet service provider. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Site (e.g., what links you have clicked on).

Generally, the Site automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Site so that we can analyze and improve them.

Information Collected Using Cookies:

Cookies are pieces of information that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Site through the Internet.

Our cookies do not, by themselves, contain Personal Information. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Site and may associate that information with your IP Address or geolocation.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. However, if you refuse to accept cookies, you may experience some inconveniences, especially when interacting with some of the most popular features of the Site.

Aggregate Information:

We collect statistical information about how users, collectively, use the Site (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you or your web browser.

Information Collected from Third Parties:

There may be occasions when we collect information about you from a third party. In such instances, we will determine whether we would have been entitled to collect such information from you and to the extent we would not have been entitled to do so, we will destroy or de-identify such information as soon as reasonably practicable.

HOW, AND WITH WHOM, IS MY INFORMATION SHARED?

We may disclose your Personal Information to other related entities within our corporate group for our own business purposes. We operate in various countries around the world and may disclose your Personal Information to our related entities located in the United States of America, Canada, and Australia.

IP Address Information:

While we collect and store IP address information, that information is not made public. When permitted by applicable law, we do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third Party Site through the Site, for example by clicking on links to those Third Party Site from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Site, and you are responsible for reading and understanding those Third Party Site’ privacy policies. This Privacy Policy only governs information collected by us for the purposes outlined in this Privacy Policy, including information collected on the Site. We do not share SMS consent or phone numbers for the purposes of SMS with third parties. 

Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Site and their Site or websites, which facilitates improving both their Site and how our Site interface with them.

Email Communications with Us:

As part of your interactions with us and use of the Site, you may occasionally receive email and other communications from us, such as communications responding to your inquiries.

Information Shared with Our Agents and Service Providers:

We may contract with third-party service providers (the “Service Providers”) that perform certain tasks and services on our behalf to help us conduct our business, including in relation to the Site and its functionality, business analytics, communications, and advertising. We may need to share Personal Information with our Service Providers in order to provide products, services and / or the Site to you. In these cases, we may share data to our Service Providers directly or through APIs (Application Programming Interfaces) and share only the information needed for the Agent or Service Provider to perform the relevant services. Where information is shared with these Service Providers, we will take all reasonable steps to ensure that third parties observe the confidential nature of such information. Some of these Service Providers may be located outside of the jurisdiction in which you are located, which we have indicated below. Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. Other than in fulfillment of our contractual obligations or as outlined below, we do not share your Personal Information with third parties, including our Site Providers.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if substantially all of our assets were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. We will notify you of such an occurrence as described in the "What Happens When There Are Changes to this Privacy Policy " section above. We reserve the right to disclose your Personal Information if required for the purposes transferring business assets in respect or a sale, or as otherwise permitted to do so by law.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Use, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and you will be able to prevent the sharing of this information.

Retention Period:

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. Generally, we maintain backups and historical records of Personal Information in the ordinary course of our business, and all data, except data stored solely by third party providers, are subject to this retention policy. Notwithstanding the above, there are certain criteria that may impact the retention period, including: (i) the length of time we have an ongoing relationship with you and provide products to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

IS INFORMATION ABOUT ME SECURE?

The security of your Personal Information is important to us. We follow generally accepted industry standards to help protect your Personal Information including without limitation:

• limiting access to your Personal Information to employees on a need-to-know basis;
• requiring employees to sign confidentiality agreements to protect confidential information, including your Personal Information;
• ensuring that Service Providers sign confidentiality agreements to maintain the confidentiality of your Personal Information and not to use it for any unauthorized purposes;
• ensuring that data shared with Service Providers is limited to only data needed to complete their respective duties;
• not storing your billing information or credit card information beyond use in a transaction;
• evaluating of all Service Providers before implementation;
• conducting annual security reviews internally to reevaluate all Service Providers and our system, to continue to ensure the highest level of security; and
• storing your Personal Information in encrypted secure systems which protect it from unauthorized access or use.

We seek to protect Personal Information to ensure that it is kept private; however, no method of transmission over the Internet, or method of electronic storage, is ever 100% secure. Therefore, while we strive to protect your Personal Information, we cannot guarantee its absolute security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If you have reason to believe that your interaction with us is no longer secure or that your Personal Information has been accessed, used or disclosed improperly or without your authorization, please immediately notify us at [email protected].

WHAT INFORMATION OF MINE CAN I ACCESS?

Users can access and delete cookies through their web browser settings.

In addition, certain users may have additional Personal Information rights based on where they live. Please see Additional Privacy Rights and Data Protection Practices for more information.

WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

You can use some of the features of the Site or otherwise interact with us without providing certain Personal Information (e.g., phone numbers and email address), thereby limiting the type of information that we collect. Where possible, we will allow you to interact with us anonymously or using a pseudonym. However, for most of our functions and activities we usually need your name and contact information.

You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our services and features. Please note that if you opt out of disclosing certain information, we may not be able to remove your Personal Information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt out request).

In addition, certain users may have additional Personal Information rights and choices based on where they live. Please see Additional Privacy Rights and Data Protection Practices for more information.

ADDITIONAL PRIVACY RIGHTS AND DATA PROTECTION PRACTICES

The laws in certain jurisdictions require us to provide users, to the extent those laws apply to such users, with certain rights and information. This means that certain users may have additional rights and choices based on where they live, and with respect to those users, to the extent this portion of the Privacy Policy conflicts with any other portion of this Privacy Policy, this portion of the Privacy Policy shall supersede and control. We have tried to provide links to websites that provide more information below. If you feel that this list does not cover your rights, please immediately notify us at [email protected].

If you are a resident of the European Union, we will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”). For information submitted using the Site, the Company is the data controller, as defined under GDPR. In accordance with GDPR, as a data subject you will be accorded with any applicable rights under GDPR. To learn more about your GDPR privacy rights, visit https://eugdpr.org/the-regulation/ . Further, list of European Union data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 .

If you are a resident of Canada, Canadian law may provide you with additional rights regarding our use of your Personal Information. To learn more about your Canada privacy rights, visit https://www.priv.gc.ca/en/ .

If you are a resident of Australia, we will process your Personal Information in compliance with the Privacy Act 1988 (Cth) (“Australian Privacy Act”). You will be provided with all rights granted under the Australian Privacy Act, including the right to access the Personal Information we hold about you and to seek correction of such Personal Information (unless there is an exception to such disclosure which applies under the Australian Privacy Act or other relevant privacy legislation). If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the Australian Privacy Principles (unless it would be unreasonable to do so).

If you wish to make a complaint about our handling of your Personal Information, please contact us at [email protected] . We will endeavour to respond to any complaints as soon as possible. If you are dissatisfied with our response, you have the right to make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or other means outlined at https://www.oaic.gov.au/contact-us . To learn more about your Australian privacy rights, visit https://www.oaic.gov.au/ .

You may also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Information infringes applicable law. However, the Company encourages any such user to contact us first at [email protected], and we will do our very best to promptly address such user’s issue(s) and resolve the concern(s).

The rights and options described above are subject to limitations and exceptions under applicable law, including, without limitation, the GDPR. In situations in which we process Personal Information on behalf of a user, we may refer the request to the relevant user and cooperate with their handling of the request, subject to any special contractual arrangement with that user. Typically, your exercise of any applicable rights will not have retroactive effect. These rights will not affect our ability to continue processing data in lawful ways.

The Company is committed to the free exercise of these rights without fear of being denied the opportunity to use the Service. To exercise any right or make any request, please notify us at [email protected]. We will respond to your request in accordance with the applicable law that governs the collection, use and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.