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WD-40 Company Privacy Policy

Effective as of March 24, 2011

WD-40 Company ("WD-40 Company", "we", or "us") takes the privacy of those visiting our web sites ("you") very seriously. We provide this Privacy Policy (the "Policy") because you have the right to know what information we collect, how it is protected and used, and the circumstances under which it may be disclosed. This Policy describes our use and sharing of personally identifiable information, which includes your full name, email address, mailing address, telephone number, or credit card number ("PII") that you may voluntarily provide to us if and when you register for certain services. The term "User" refers to visitors and to those who register for certain services. This Policy applies to the services offered by WD-40 Company on its web sites, including any WD-40 Company-branded web site, the WD-40 Fan Club (www.mywd40.com), (collectively, the "Web Site"), and any other features, content, or applications offered from time to time by us in connection with the Web Site (collectively, the "Services").

I.
Personally Identifiable and Other Information We Collect
II. Use of Information Collected
III. Information Sharing and Disclosure
IV. Choice and Opt-Out
V. Changing Your Information
VI. Third Party Advertisers
VII.
Security
VIII. Links to Other Sites
IX. Bulletin Boards/Chat Rooms
X.
Changes in this Privacy Policy
XI.
Contact Information


I. Personally Identifiable and Other Information We Collect

We collect information from Users of the Web Site.

A. Information About Our Users

The minimum age to register for the Services is 13 years old. WD-40 Company does not knowingly collect PII from children under the age of 13. Children under the age of 13 should not provide any information on the Web Site. We ask that parents supervise their children while the children are online.

Users may wish to request information about our company or our products, to become a member of our Fan Club, to participate in our Services (such as contests, offers, and surveys), or to submit suggestions, photos, videos, and other information to us. In connection with each of those items you may be asked to provide information that could identify you personally, such as your name, company, title, phone number, email address, mailing address, and/or credit card number. In addition, if you wish to register for certain Services, download certain information, or upload information like photos and videos, you may be required to provide certain additional information that can identify you personally, such as your Member Name or username, your password, contact information, occupation, workplace, hobbies, interests, age, marital status, education, and children, and other information. Users are responsible for maintaining the confidentiality of any passwords they are given to access our Web Site, and are fully responsible for all activities that occur under their passwords. Information that you voluntarily provide that is not required by us is provided by you in your sole discretion.

B. Aggregated Data

WD-40 Company compiles anonymous, aggregated statistics from Users for a variety of internal and marketing purposes. Such purposes include benchmarking, determining appropriate levels of hardware, determining the numbers of employees that will be needed to provide the Services to our Users, and reporting numbers of Users and/or web sites that use the Services. This anonymous, aggregated data is not used in any way that can identify an individual person or User.

C. Web Site Viewing Information

1. Cookies

WD-40 Company uses cookies to make the Web Site easier to use and more useful. When you visit the Web Site our servers send a cookie to your computer. By themselves, cookies do not personally identify you, but instead simply recognize the web browser you are using. If you do not otherwise affirmatively provide PII about yourself to us, either by registering with us, responding to a promotional offer, or filling out a form, you will remain anonymous to WD-40 Company.

There are two types of cookies: session and persistent. Session cookies disappear from your computer when you close your web browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. You can remove persistent cookies by following directions provided in your Internet browser's "help" file. If you have chosen to identify yourself to us then we use session cookies containing encrypted information to allow us to uniquely identify you.

WD-40 Company uses persistent cookies that only we can read and use to identify browsers that have previously visited the Web Site. When a User provides us with PII, a unique identifier is assigned to them. This unique identifier is associated with a persistent cookie that we place on the User's web browser. We are very careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. If you disable your web browser's ability to accept cookies, you will be able to navigate our Web Site, but you will not be able to successfully use certain of the Services.

Some of our business partners (e.g., advertisers) may use cookies on our Web Site. We have no access to or control over these cookies. See "Third Party Advertisers."

2. Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information does not identify individual users. Log files include internet protocol ('IP') addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Web Site, to see how users move around the Web Site, and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to PII. We collect certain anonymous information from your visit to the Web Site via industry standard and commercially available web analytics solutions, including Omniture Web Analytics.

3. Clear Gifs (Web Beacons)

We use clear gifs (a.k.a. web beacons) that help us better manage content on the Web Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers' PII. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see "Choice and Opt-Out."

Third party applications (such as widgets) created by third party developers may also be available on the Web Site. Third party applications are small bits of software, often with interactivity, that can be installed into Users' profiles or shared with other Users. However, WD-40 Company does not control the third party developers, and cannot dictate their actions. When a User engages with a third party application, that User is interacting with the third party developer, not with WD-40 Company. WD-40 Company encourages Users not to provide PII to the third party's application unless the User knows the party with whom it is interacting.

II. Use of Information Collected

WD-40 Company uses the information you provide to us to give you access to information you request and to perform the Services. WD-40 Company may also use the information that you provide to us to contact you to further discuss your interest in our company and our Services, and to send information regarding our company or partners (such as marketing promotions and events). We store any voluntarily provided email we receive for archival purposes and for our own marketing purposes if we feel that it is consistent with the nature of the inquiry. The information is collected and stored in a manner that is appropriate for the nature of the data that we collect and the need to fulfill your request. This information is not shared with third parties for their own use, unless you specifically authorize such sharing.

While WD-40 Company does not itself currently collect credit card information, we may do so in the future. If we do collect credit card information in the future, the sole purpose of the collection and use of that information will be to effect transactions for the sale of products. Currently, however, any purchases through our Web Site are not handled by us but are handled by a third party, as described in Section III.B. below.

To locate other Users that you may already know in the physical world, we allow Users to search for registered users using certain PII (i.e., full name or email address). WD-40 Company also allows Users to browse for certain non-PII information to help connect with other Users (e.g., hobbies or interests). We may also enable Users to publicly display some PII if they choose to do so. Search engines may index the portion of a User's PII that is voluntarily publicly displayed by a User.

If you have consented to receive promotional materials (e.g., newsletters) or notifications from us, we may periodically use your email address to send you such materials related to the Services. If you want to stop receiving such materials from us you can change your profile settings under "Profile." In addition, you can opt out of, or unsubscribe from, the No-Rust and other reminder e-mails at any time by following the instructions contained in those e-mails.

Non-PII information you provide to us in response to: (i) multiple choice questions like "Hobbies and Interests" and "Employment"; (ii) information you add to open-ended questions; and, (iii) other non-PII about you, may be used to customize the online ads, special promotions, e-mails, and other marketing information you encounter to those we believe are aligned with your interests. For example, based on your hobbies we might display an advertisement about one of our products that you may not be familiar with, or a about an event that you may be interested in. The information used for this feature does not provide your PII or identify you as an individual to third parties. If you would like to disable advertising customization for these types of information, please visit "Profile" under the Fan Club.

III. Information Sharing and Disclosure

A. Non-Personally Identifiable and Aggregated Information

As described elsewhere in this Policy, we may customize the advertising and marketing messages you receive on the Web Site, or may work with outside companies to do so. Your non-PII may be shared with these companies so this customization can be accomplished. WD-40 Company prohibits these companies from sharing your non-PII with any third party or from using it for any other purpose. Anonymous click stream, number of page views calculated by pixel tags, and aggregated demographic information may also be shared with WD-40 Company's advertisers and business partners.

We may also perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Web Site. In addition, we may in the future inform advertisers of such information as well as the number of users that have been exposed to or clicked on their advertising banners. We will, however, provide only aggregated data from these analyses to third parties.

We do not link aggregate user data with PII.

B. Personally Identifiable Information

We share PII with third parties in particular situations.

WD-40 Company may sometimes permit third parties to offer registration-based services through the Web Site. WD-40 Company is not responsible for any actions or policies of such third parties and users should check the applicable privacy policy of such parties when providing PII to them.

We may in connection with the Web Site use the services of third parties (i.e., technology consultants and CRM vendors), who may, in the course of providing services to us, be given access to the information you have provided to us. Each of these service providers is contractually obligated to provide services to us in a manner consistent with this Policy.

WD-40 Company employees, agents and contractors must have a business reason to obtain access to your PII. WD-40 Company may share your PII with those who help us manage or provide the Services (e.g., message board administration, statistical analyses, data processing, and order fulfillment), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfillment aspects of contests and promotions.

These outside contractors or agents may temporarily store some information on their servers, but they may only use your PII to provide WD-40 Company with a specific service and not for any other purpose. WD-40 Company may also provide your PII to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your PII. WD-40 Company also may share your PII with companies that are affiliated with WD-40 Company if we have a business reason to do so.

If in the future we intend to share personally identifiable information with third parties acting other than as our agents or service providers, we will provide you with the opportunity to opt-out prior to the sharing.

The information gathering and order processing for http://www.amazon.com in the "Shop" section of the Web Site are handled by a third party vendor, Amazon.com. Amazon.com's privacy policy provides that, except as explicitly set forth in their privacy policy (which policy can be amended by them at any time), Amazon.com will not disclose your Personal Information (as defined in their privacy policy) to third parties without your express permission. Amazon.com's credit card transactions are handled with industry-standard SSL encryption to protect your information.

C. Agents and Service Providers

We use a credit card processing company when necessary to bill for products and services. This company does not retain, share, store or use PII for any other purposes.

We use other third parties to provide shopping services, and a community environment/social network, on our Web Site. When you sign up for the Services we will share the PII that is necessary for the third party to provide the Services.

These third parties are prohibited from using your PII for any other purpose.

D. Law Enforcement and Assignment

We reserve the right to disclose your PII pursuant to a subpoena or other judicial or administrative order, when required by law, when we believe that disclosure is necessary to protect our rights, the rights of our affiliated companies, the rights or safety of any individual or the public, and rights of our Users or any third party. In addition, if WD-40 Company sells all or part of its business, makes a sale or transfer of all or a material part of its assets, or is otherwise involved in a merger or transfer of all or a material part of its business, WD-40 Company may transfer your PII to the party or parties involved in the transaction as part of that transaction.

IV. Choice and Opt-Out

We provide you the opportunity to "opt-out" of having your PII used for certain purposes, when we ask for this information. For example, if you sign up for the Services but do not wish to receive any additional marketing material from us, you can so indicate your preferences in your Profile.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication. You may also update your profile on the sites that contain a profile and change your newsletter and promotional communications' preferences.

You will be notified when your personal information is proposed to be collected by any third party that is not our agent or service provider, so you can make an informed choice as to whether or not to share your information with that party.

V. Changing Your Information

Users and Customers may update or change their PII by editing their Profile. To update or delete User information on the WD-40 Fan Club web site please login to www.mywd40.com with your WD-40 Company Member Name and password.

VI. Third Party Advertisers

As explained in the Amazon.com Privacy Policy here, Amazon.com may use PII to personalize and display advertisements on that web site. Amazon.com uses cookies which enables their systems to recognize your device and to provide features such as 1-Click, purchasing, Recommended for You, personalized advertisements on other Web sites (e.g., Amazon Associates with content served by Amazon.com and Web sites using Checkout by Amazon payment service), and storage of items in your Shopping Cart between visits.

VII. Security

The security of your PII is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology ("SSL").

We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

VIII. Links to Other Sites

Our Web Site may contain links to other web sites. WD-40 Company is not responsible for the privacy practices or the content of non-WD-40 Company Web Sites. Non-WD-40 Company linked Web Sites are not under the control of WD-40 Company and WD-40 Company is not responsible for the contents of any such linked sites, any link contained in such linked sites, or any changes or updates to such sites. WD-40 Company is not responsible for any transmission received from any non-WD-40 Company Web Sites including any webcasting or other method of transmission. Links to non-WD-40 Web Sites are provided only as a convenience. WD-40 Company does not endorse any link made available through our Web Site that is not a WD-40 Company Web Site. We encourage all users of our Web Site to read the privacy policies of each and every Web Site visited when linking directly from our Web Site.

This Policy applies only to information collected by the Web Site.

IX. Bulletin Boards/Chat Rooms

If you use a bulletin board or chat room on the Web Site, you should be aware that any PII you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the PII you choose to submit in these forums.

In addition, if you provide to WD-40 Company directly, or you choose to post on the portions of the Web Site that are viewable by others, any comments, ideas, or suggestions that are accompanied by your name (which is PII), or your first name and your last name initial, WD-40 Company may use both your comments, ideas, and suggestions, and your name, for our marketing purposes without compensation or acknowledgment of any kind.

X. Changes in this Privacy Policy

We reserve the right to modify this Policy at any time, so please review it frequently. If we make material changes to this Policy, we will notify you here, by email, or by means of a notice on our home page. Your continued use of the Web Site after we post a revised Policy constitutes your acceptance of the new Policy and its terms. If, however, we materially change our practices regarding the collection or use of your PII, your PII will continue to be governed by the Policy that was in place at the time you provided the PII unless we provide notice to you of the changes in the Policy and you do not object to the change.

XI. Contact Information

If you have any questions about this Privacy Policy, please contact us at: wd40legal@wd40.com or at the address or telephone number listed below.

Corporate Headquarters
WD-40 Company Customer Relations
P.O. Box 80607
San Diego, CA 92138-0607
USA
Tel: 888-324-7596