KOLBE WINDOWS & DOORS PRIVACY POLICY

Effective Date: April 25, 2023

TABLE OF CONTENTS

  1. 1. WHO WE ARE
  2. 2. HOW TO CONTACT US
  3. 3. WHY WE COLLECT DATA AND HOW WE COLLECT IT
  4. 4. PROTECTING YOUR PRIVACY GENERALLY
  5. 5. CHILDREN’S PRIVACY
  6. 6. TYPES OF INFORMATION WE COLLECT
  7. 7. DO NOT TRACK SIGNALS
  8. 8. INFORMATION WE SHARE WITH THIRD PARTIES
  9. 9. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA
  10. 10. SECURITY
  11. 11. LINKS TO THIRD-PARTY SITES
  12. 12. DATA RETENTION
  13. 13. ACCESSIBILITY
  14. 14. NOTICE TO NEVADA RESIDENTS
  15. 15. NOTICE TO CALIFORNIA RESIDENTS
  16. 16. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA

1. WHO WE ARE


This Privacy Policy applies to Kolbe & Kolbe Millwork Co., Inc., and our subsidiaries, Kolbe Galleries, Inc. and Kolbe ServicePro, Inc. (collectively, “Kolbe,” “we,” “our,” or “us”). Kolbe sells its high-quality doors and windows through a network of authorized distributors. Kolbe also sells some parts and services directly to consumers. Kolbe operates publicly available websites at kolbewindows.com, kolbegallerytwincities.com and kolbeservicepro.com (“Sites”) where individuals and entities may obtain more information about Kolbe’s products and services (“Services”).

Some of the data Kolbe collects is considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”). Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual. It does not include deidentified or anonymized data.

The purpose of this Privacy Policy is to disclose to you how we collect, use, and share Personal Data and how we attempt to safeguard the Personal Data we collect and process. We are committed to securing the Personal Data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws. We may update this Privacy Policy from time to time. When we do, we will post an amended version of the Privacy Policy on this website. Please review this Privacy Policy periodically.


2. HOW TO CONTACT US


If you have any questions regarding data protection, please contact us:

Kolbe & Kolbe Millwork Co., Inc.
Attn: Privacy Team
1323 S. 11th Avenue
Wausau, WI 54401
privacy@kolbewindows.com
Contact Us – Privacy Request Webform


3. WHY WE COLLECT DATA AND HOW WE COLLECT IT


We collect, process, and use Personal Data to allow you to provide our products, Services and Sites to you. For example, we use the Personal Data we collect to:

  • Communicate with you;
  • Provide you with information, quotes, and offers;
  • Provide our products and Services;
  • Connect you with our distributors and service partners;
  • Process your account registration (where applicable);
  • Provide you with support;
  • Personalize your experience on our Sites;
  • Improve our products and services;
  • Measure the performance of our Sites and Services;
  • Audit current interaction and transactions with the consumer;
  • Help to improve the security and integrity of the Sites and Services;
  • Maintain, improve and customize our products, Sites, and Services;
  • Investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our terms of use;
  • Efficiently maintain our business;
  • Comply with applicable law; and
  • Defend our legal rights.

We obtain Personal Data directly from you, through cookies and other technologies, through your devices, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.


4. PROTECTING YOUR PRIVACY GENERALLY.


a. Industry-Standard Protection. We utilize industry-standard security measures to safeguard the information we collect, maintain, and use. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction. However, we do not and cannot guarantee the performance or adequacy of such security measures.

b. Limitation on Access. Access to any Personal Data we collect and store is generally restricted to our employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry standard protocols to maintain the confidentiality, security, and integrity of Personal Data.


5. CHILDREN’S PRIVACY.


We do not intentionally collect any Personal Data from consumers under the age of sixteen (16) years of age. We do not sell Personal Data of any individuals, including individuals under the age of sixteen (16) years.


6. TYPES OF INFORMATION WE COLLECT.


a. Information You Provide Directly To Us. We may collect the following categories of Personal Data if you provide it to us:

  • Contact information and identifiers (such as name, local and permanent address, company name, telephone number, electronic mail address);
  • Information regarding your order and/or service request (product purchased, date of purchase, purchase price, distributor name);
  • Information you provide to us when inquiring about our products or services;
  • Your social media account names / handles and any direct message information you have with us; and
  • Any other information you provide to us.

b. Information We Collect Via Tracking Technology.

We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “cookies”) to collect information as you navigate the Sites. Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile, or other devices (e.g., smartphones or tablets). The information collected includes:

  • Unique personal identifiers (device identifiers, cookies, beacons, pixel tags, mobile ad identifiers and other forms, or persistent or probabilistic identifiers that can be used to identify a particular consumer or device);
  • Internet or other electronic network activity information (browsing history, search history, and information regarding your interaction with the Sites, application, or advertisement); and
  • Your location data when you use our Where to Buy feature to locate one of our distributors.

For more information on our use of tracking technologies and to make changes to your settings, please visit our Cookie Policy.

You can also control the use of cookies at the browser level by setting your web browser controls to accept or refuse cookies. If you choose to block all cookies (including essential cookies) you may not be able to access all or parts of our Sites and Services. In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information on this, please visit the websites: http://www.aboutads.info/choices/ or http://www.youronlinechoices.com or http://globalprivacycontrol.org.

c. Information our Distributors or Other Service Providers Provide to Us. Our distributors and service providers may provide Personal Data about you to us if they need the information to provide products or services to you, such as quotes, orders, installation services, warranty information, services, or part replacements.


7. DO NOT TRACK SIGNALS.


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


8. INFORMATION WE DISCLOSE TO THIRD PARTIES


We do not sell Personal Data or share it for contextual or targeted advertising purposes. We may provide access to Personal Data to others in the following limited ways:

  1. With service providers. We may share information with service providers who:
  1. To Meet Our Legal Requirements or Exercise Our Rights. We may share information with third parties in the following instances:
  • When we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
  • When we reasonably believe it is appropriate to apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Data; and
  • As part of our own corporate transactions, such as during financing or any asset sale.
  1. At Your Request. We will share your Personal Data when you request or otherwise consent to the disclosures. For example, if you provide information through our Where to Buy form, we will share the information you provide with the distributor.


9. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA


We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties.

  1. You may decline to provide information. You have the right to decide not to share information with us.
  2. You may request deletion. You may submit a request to update or delete your personal data by contacting us through our online form or at privacy@kolbewindows.com.


    PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE NOT TO PROVIDE US WITH CERTAIN INFORMATION OR ASK US TO DELETE YOUR INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH SOME OF OUR SERVICES. IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.

  3. You may review and request changes to your personal data. If you have an account with us, you may use your account to access, correct, or view certain personal data we have collected which is associated with your account. You may also contact us through our online form or at privacy@kolbewindows.com to request information or changes.
  4. You may opt out of marketing communications. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls, and postal mail. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You may also contact us through our online form or at privacy@kolbewindows.com to opt out of our communications.
  5. You may control cookies used. You may opt out of cookies through your account settings in the Sites or as described in Section 6 (b) above.


10. SECURITY


When you register for an account with us, you may be required to choose or will be assigned a password which enables you to access our Sites. You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone. If your password is compromised, change your password within your account. If you believe your account may have been compromised, please notify us immediately.

We take industry standard security measures to protect your information. We also have put into place appropriate agreements and/or procedures with our service providers to ensure that your Personal Data is treated consistent with applicable data privacy and security laws. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot and do not guarantee the security of your data.


Our Sites may contain links to other websites and companies that may be of interest to you. If you click on any of those links, you will leave our Sites. We are not responsible for third-party websites. Therefore, please consult the terms of service and privacy policies of those sites when you visit them.


12. DATA RETENTION


We will store your Personal Data for as long as: (a) you maintain an account with us; (b) you continue using our Sites and Services; (c) your Personal Data is stored in our back up servers and/or services; (d) in accordance with our retention policies and schedules; and (e) as long as we are legally required to retain the Personal Data.


13. ACCESSIBILITY


We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing on our Sites or Services, please email us at privacy@kolbewindows.com. You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.


14. NOTICE TO NEVADA RESIDENTS


Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to privacy@kolbewindows.com.


15. NOTICE TO CALIFORNIA RESIDENTS


This Privacy Notice to California Consumers (“CA Notice”) is for California residents and supplements the other sections of Kolbe’s Privacy Policy. This CA Notice explains how we collect, use, and disclose your “Personal Information” (as that term is defined by California law) and how you may exercise your rights under the California Consumer Privacy Act (“CCPA”). This Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you.

NOTE: If you are a California resident and a current or former employee, job applicant, or independent contractor of Kolbe, please see our Privacy Policy for California Employees, Former Employees & Job Applicants for more information on our collection, use, and storage of your Personal Information in that capacity.

  1. NOTICE AT COLLECTION OF PERSONAL INFORMATION. To provide you with our products, Sites, and Services, we collect and process information about you, including, in some cases, Personal Information. To comply with the CCPA and to assist you in understanding our data collection and protection practices during the past 12 months:
  1. Categories of Consumer Personal Information. We collect and, in the 12 months prior to the Date of Last Revision of this Privacy Policy, have collected the following categories of consumer Personal Information:
  • Identifiers (name, postal address, online identifier, Internet Protocol address, email address, account name);
  • Unique personal identifiers (device identifier, cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology);
  • Telephone number;
  • Signature;
  • Bank account number;
  • Other financial information, including business credit history, payment behavior, and tax identification number;
  • Internet or other electronic network activity information (browsing history, search history, and information regarding consumer’s interaction with website, application, or advertisement);
  • Geolocation data;
  • Commercial information (records of personal property and personal credit information);
  • Professional or employment-related information (including employment history); and
  • Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, behavior, and abilities;
  1. Sources of Personal Information. We collect the above categories of consumer Personal Information from you, your devices, and from our distributors and service providers as described in Section 6 above.
  2. Purpose for Collection. In addition to the business purposes for which we collect consumer Personal Data described in Section 3 above, we collect consumer 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 device 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; and
  • 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.
  1. Sale and Sharing of Personal Information. Kolbe does not “sell” Personal Information, as that term is commonly interpreted. However, we do engage in targeted advertising activities that may constitute a sale or a share of Personal Information under California law. Specifically, we use Google Ad Manager, which places tools on our Sites to collect information from our site users so that Google may serve those users with targeted advertisements through other websites. The following table identifies the categories of Personal Information that Google has collected from our website users in the 12 months preceding the Date of Last Revision of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:
Category of Personal Information Categories of Third Parties
Unique personal identifiers (such as browser information, IP address, date and time of visit, device identifier, cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology) Advertising networks (Google)


The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Date of Last Revision of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information. Please note that not all categories of personal information were necessarily shared with all categories of recipients listed.
 

Category of Personal Information Categories of Third Parties
Identifiers (name, postal address, online identifier, Internet Protocol address, email address, account name) Distributors, business partners, data hosting and cloud storage providers, mailing providers, advertising service providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Unique personal identifiers (device identifier, cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology) Data hosting and cloud storage providers, cookie management service provider, advertising service providers.
Telephone number Distributors, business partners, data hosting and cloud storage providers, mailing providers, advertising service providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Bank account number Financial institutions for processing.
Internet or other electronic network activity information (browsing history, search history, and information regarding consumer’s interaction with website, application, or advertisement) Data hosting and cloud storage providers, cookie and privacy management provider.
Other financial information, including business credit history, payment behavior, and tax identification number Business partners, data hosting and cloud storage providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Geolocation data Distributors, data storage providers, security, anti-fraud, and verification providers.
Commercial information (records of personal property and personal credit information) Distributors, business partners, data hosting and cloud storage providers, mailing providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Professional or employment-related information (including employment history) Distributors, business partners, data hosting and cloud storage providers, mailing providers, providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, behavior, and abilities. Security, anti-fraud, and verification providers, client relationship management service providers.
  1. Children’s Personal Information. We do not knowingly collect Personal Information of consumers under 16 years of age and we do not knowingly sell or share the Personal Information of consumers under 16 years of age.
  2. Sensitive Personal Information. We do not use Sensitive Personal Information (as it is defined in the CCPA) for the purpose of inferring characteristics about individuals.
  3. Retention of Personal Information. We retain Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
  4. Your Rights. Under the CCPA, you have the following rights:
RIGHT TO KNOW You have the right to request that we disclose to you the Personal Information we collected about you in the 12-month period preceding your request. This right includes the right to request: (1) specific pieces of Personal Information we have collected about you; (2) categories of Personal Information we have collected about you; (3) categories of sources from which the Personal Information was collected; (4) categories of Personal Information that we sold or disclosed for a business purpose about you (if applicable); (5) categories of third parties to whom your Personal Information was sold or disclosed for a business purpose (if applicable); and (6) the business or commercial purpose for collecting or, if applicable, selling your Personal Information.
RIGHT TO DELETE You have the right to request that we delete your Personal Information that we have collected from you, with some exceptions. Note that if you request that we delete your information, we may be unable to provide you with certain offers or services.
RIGHT TO CORRECT You have the right to correct inaccurate Personal Information we maintain about you.
RIGHT TO OPT OUT OF SALE If we sell or share Personal information, you have the right to opt out of the sale or sharing. Kolbe does not sell Personal Information. Kolbe engages in limited cross-context behavioral advertising as described above. You may opt out of such advertising activities.
RIGHT TO LIMIT PROCESSING OF SENSITIVE PERSONAL INFORMATION 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 and disclosure. Kolbe does not use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.
RIGHT TO NON-DISCRIMINATON You have the right to non-discrimination for exercising your CCPA rights. This means we cannot deny you goods or services, charge you different prices, or provide a different level of quality of goods or services just because you exercise your rights under the CCPA. Kolbe will not and does not discriminate against you or other customers for exercising any of your CCPA rights.
 
  1. How to Exercise Your Rights.
 

Right to Submit a Request to Know, Delete and/or Correct: You may submit a request to know, delete and/or correct by emailing us at privacy@kolbewindows.com or you may contact us through our online form. If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident, if applicable.

Our Process for Verifying a Request to Know, Delete, and/or Correct. 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. For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt Out of Sale or Sharing of Personal Information. You have the right to opt-out of the sales of your Personal Information and the sharing of your Personal Information for cross context behavioral marketing. You may exercise your right to opt out by following the instructions on our Do Not Sell or Share My Personal Information page. As set forth above, we do not sell your Personal Information, but can note in our records that you would like to opt out of any future sales through the Do Not Sell or Share My Personal Information webform. To opt out of “sharing” of your Personal Information via cross context behavioral advertising, please go to our cookie settings and turn off Advertising / Targeting Cookies.

 
  1. Shine the Light Law. California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). Kolbe does not sell or disclose information to third parties for their direct marketing purposes.
 

16. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA.

 

The General Data Protection Regulation (“GDPR”) applies to individuals located in the European Economic Area (“EEA”). The GDPR allows us to collect and use personal information from individuals within the EEA only for one or more of the following reasons:

  1. To fulfill a contract we have with you;
  2. When we have a legal duty;
  3. When it is in our legitimate interest; or
  4. When you provide consent.

We do not operate in the EEA or specifically direct our business to consumers in the EEA. However, we recognize some of our website users, customers and prospective customers could be located within the EEA. If you reside in the EEA, you have a number of rights under data protection laws in relation to the way we process your Personal Data, which are set forth below. You may contact us directly to exercise any of these rights, and we will verify your request and, if appropriate, respond to any request received from you within one month from the date of the request. In exceptional circumstances we may need to extend this timescale, but we will always tell you in advance if we do, and our reasons why.

Right 1 A right to access personal data held by us about you, as well as information about how we are using your data.
Right 2 A right to require us to rectify any inaccurate personal data held by us about you.
Right 3 A right to require us to erase personal data held by us about you, and where the personal data has been made public, for other controllers processing the personal data to also erase links to, or copy or replication of, such personal data. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4 A right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 5 A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organization, at your request.
Right 6 A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you).
Right 7 A right to withdraw your consent when we are relying on your consent to use your personal data (for example, you may opt out of marketing emails even if you previously consented to receiving marketing information about our services or products).
 

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, please get in touch with our team through the contact information provided in Section 2 of this Privacy Policy. You may also reach out to your applicable Data Protection Authority (“DPA”) for more information. There is a DPA located in each EU Member State.