Privacy Policy

Watkins Manufacturing Corporation (“Watkins Wellness,” “Watkins,” “we,” “us,” or “our”) want you to be familiar with how we collect, use, and disclose Personal Information in connection with our business operations. This Privacy Policy describes our practices in connection with Personal Information that we collect through:

• Phone interactions;
• Websites operated by us from which you are accessing this Privacy Policy, which includes but is not limited to https://www.calderaspas.com/, https://www.endlesspools.com/, https://www.hotspring.com/, https://www.watkins.pro/,  https://sauna360.com/, https://tylo.com/, https://helosauna.com/, and any virtual assistants or chatbots we operate (the “Websites”);
• Software applications that operate and/or complement our products that we make available for use on or through computers and mobile devices (the “Apps”);
• Social media properties from which you are accessing this Privacy Policy , which includes but is not limited to https://www.facebook.com/calderaspas, https://www.facebook.com/HotSpringSpas, https://www.instagram.com/calderaspas/, https://www.instagram.com/hotspring_spas/, https://www.facebook.com/tylosaunanorthamerica/, https://www.instagram.com/tyloglobal/, https://www.facebook.com/helosaunas, https://www.instagram.com/helosaunas/, https://www.facebook.com/EndlessPools, and https://www.instagram.com/endlesspools/ (collectively, our “Social Media”);
• HTML-formatted email messages or other communications that we send to you that link to this Privacy Policy (“Emails”); and
• Any other offline business interactions you may have with us, including in-person interactions, such as at trade shows or our facilities, during in-person market research, and at retail stores where our products are sold (“Offline Interactions”).

Click here for additional information for residents of U.S. states.

Collectively, we refer to Phone Interactions, the Websites, Apps, our Social Media, Emails, and Offline Interactions as the “Services.” We encourage you to read this Privacy Policy before using the Services or submitting your Personal Information to us.  Your use of the Services signifies that you agree with all the terms of this Privacy Policy.

CATEGORIES AND SOURCES OF PERSONAL INFORMATION COLLECTED

“Personal Information” is information that identifies an individual or relates to an identifiable individual. We generally collect Personal Information directly from you. However, we may also collect your Personal Information indirectly from third parties as described below.
When we collect Personal Information about you indirectly, we will take reasonable steps to notify you as soon as practicable that we have done so, where required by applicable law.

We collect the following categories of Personal Information:

We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

PERSONAL INFORMATION PROCESSING PURPOSES

We use Personal Information for legitimate business purposes, including:

Individuals in the EEA/UK: Please view the EEA/UK PRIVACY SUPPLEMENT below for more information regarding our legal basis for processing Personal Information.

DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Information to third parties and for the purposes described below, depending on each specific jurisdiction and applicable law:

By using the Services, you may elect to disclose Personal Information on message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media), or through which you are able to send messages through the Services. Please note that any information you post or disclose in this context will become public and may be available to other users and the general public.

COOKIES AND SIMILAR TECHNOLOGIES

We and our service providers automatically collect certain information when you use our Services, like details about your browser and device, how you use our apps, and information from cookies and similar technologies. We also collect general demographic data and information that has been aggregated so it doesn’t identify you personally.

We and our service providers may collect information automatically in a variety of ways, including:

• Your browser or device
  
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services (such as our apps) you are using. We use this information to ensure that the Services function properly.

• Your use of our apps
  
  • When you download and use our apps, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to our app based on your device number.

• Cookies
  
  • Cookies are small files saved on your device. We use cookies to keep our Services secure, make navigation easier, show you relevant information, and understand how people use our Services. We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We currently respond to browser do-not-track signals.
  • If you do not want information collected using cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If you don’t accept cookies, some features on the Services may not work as well. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

• We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

• Pixel tags and other similar technologies
  
  • Pixel tags (also known as web beacons and clear GIFs) may be used to see how people use our Services and emails, and to measure how well our marketing works.

• Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
  
  • We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without you being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

We may use and disclose information collected automatically for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat information collected automatically as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine information collected automatically with Personal Information. If we do, we will treat the combined information as Personal Information while it is combined.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the CONTACTING US section below.

EMAIL MARKETING & SMS CHOICES

You have choices regarding marketing-related communications and/or SMS communications. Where required by applicable law, we will ask for your prior opt-in consent. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the unsubscribe instructions in any such message or by contacting us in accordance with the CONTACTING US section below.  You may opt out of SMS text messages at any time by replying “STOP”.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.

RIGHTS AND REQUESTS

If you would like to request to access/review, correct, update, suppress/delete, object to, restrict or opt out of the processing of Personal Information, withdraw your consent where relied upon for processing (which will not affect the lawfulness of processing prior to the withdrawal), issue a complaint about our processing of your Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent that these rights are provided to you by applicable law), please contact us in accordance with the CONTACTING US section below. We will respond to your request consistent with applicable law. If you are a resident of California, Nebraska, or Texas, please refer to the U.S STATE CONSUMER PRIVACY SUPPLEMENT below for more information about the requests you may make under applicable law.

In your request, please make clear the nature of your request (i.e., what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or the limitations you would like to put on our use of your Personal Information). For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after completion of such purchase or promotion). Further, certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations.

Depending on your jurisdiction, you may also lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. For example, a list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/. Information regarding the Office of the Australian Information Commissioner is available at: https://www.oaic.gov.au/privacy/privacy-complaints. Information regarding the New Zealand Office of the Privacy Commissioner is available at: https://www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner.

RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained as outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. The criteria used to determine our retention periods include:

• The length of time that we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of transactions or communications for a certain period before we can delete them); or
• Whether retention is advisable considering our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties. This includes any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media.

THIRD-PARTY ADVERTISING

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including using pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the device on which you are accessing this Privacy Policy, click the “cookie preferences” link at the footer of this website.

THIRD-PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to make payments to us using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country or region where we have facilities or engage service providers. By using the Services, you understand that your Personal Information will be transferred to countries outside of your country or region of residence, including but not limited to the United States, Canada, the EU, India, Mexico, and the UK, which may have data protection rules that are different from those of your country or region. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries or regions may be entitled to access your Personal Information.

Some countries outside of the EEA/UK are recognized by the European Commission and/or the UK government as providing an adequate level of data protection according to EEA/UK standards: the list of the EEA’s adequate jurisdictions is available here, and the list of the UK’s adequate jurisdictions is available here. For transfers from the EEA or the UK to countries not considered adequate by the European Commission or the UK government (as applicable), we have put in place adequate measures, such as the standard contractual clauses adopted by the relevant authority to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the CONTACTING US section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.  We encourage you to check this page regularly because your continued use of the Services following any changes to the Privacy Policy will constitute your acceptance of such change.

CONTACTING US

Watkins Manufacturing Corporation located at 1280 Park Center Dr, Vista, CA 92081 is responsible for the collection, use, and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, concerns about our use of Personal Information, or believe that we have not complied with applicable privacy laws, you can contact us by email at custsvc@watkinsmfg.com or clicking here https://www.hotspring.com/privacy-policy/privacy-request, by calling 1-800-999-4688 (US Only), or by mail at 1280 Park Center Dr, Vista, CA 92081.

When contacting us, please provide as much detail as possible regarding your question or concern. We take all privacy inquiries seriously and will work to address and resolve them in an efficient manner.

You may also contact Kevin Edwards, Director of Data Analytics and Privacy at our parent company Masco Corporation at consumerprivacy@mascohq.com or 1-833-724-0948.

EEA/UK PRIVACY SUPPLEMENT

We process Personal Information based on the following legal bases:

U.S. STATE CONSUMER PRIVACY SUPPLEMENT

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business or commercial purposes, including within the preceding 12 months. The chart also details the categories of Personal Information that we “sell” to third parties or “share” for purposes of cross‑context behavioral or targeted advertising, including within the preceding 12 months.  For further details, please see above under the DISCLOSURE OF PERSONAL INFORMATION section.

We retain each category of Personal Information, including Sensitive Personal Information, as described above under the RETENTION OF PERSONAL INFORMATION section.

We have not engaged in such activities in the preceding 12 months. Without limiting the foregoing, we do not sell or “share” Personal Information, including Sensitive Personal Information, of minors under 16 years of age.

We collect, use, and disclose Personal Information for the purposes described above under the PERSONAL INFORMATION PROCESSING PURPOSES section.

We also collect, use, and disclose Sensitive Personal Information for purposes of performing services for our business; providing goods or performing services as requested or reasonably expected by you; ensuring safety, security, and integrity; countering wrong or unlawful actions; short-term transient uses; servicing accounts; providing customer service; verifying customer information; processing payments; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use Sensitive Personal Information for additional purposes.

We collect Personal Information from several sources as described above under the CATEGORIES AND SOURCES OF PERSONAL INFORMATION COLLECTED section.

Individual Rights and Requests

You may, subject to applicable law, request that we:

1. Disclose to you the following information:
   1. The categories of your Personal Information we collected and the categories of sources from which we collected your Personal Information;
   2. The business or commercial purpose for collecting your Personal Information; and
   3. The categories of your Personal Information that we disclosed and the categories of third parties to whom we disclosed your Personal Information;
2. Correct inaccuracies in your Personal Information;
3. Delete your Personal Information; and/or
4. Provide the specific pieces of your Personal Information, including a copy in a portable format.

To make a request, please use our webform https://www.hotspring.com/privacy-policy/privacy-request/email us at custsvc@watkinsmfg.com or call us at 1-800-999-4688 (US only).

You have the right to be free from unlawful discrimination for exercising your rights under applicable law.

We will verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Information subject to the request. For your protection, we may need to request information such as your name, email address, mailing address, and purchase history to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

Opt-out Preference Signals

We also process opt-out preference signals, such as the Global Privacy Control. These signals set your opt-out preferences only for the particular browser or device you are using and any consumer profile that we associate with that browser or device. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Sharing your Personal Information with Third Parties for Direct Marketing Purposes

If you prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates and unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by contacting us as described in the CONTACTING US section above.

Appeals

To the extent available under applicable law, if we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us as described in the CONTACTING US section above.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted above. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use that information only in a de-identified form and will not attempt to re-identify the information.