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BlueTriton Brands, the company that produces and distributes numerous brands of
bottled water including Poland Spring® 100% Natural Spring Water, would like to
alert the public of a scam asking consumers to wrap a Poland Spring®
advertisement around their vehicle in return for financial compensation. We do
not have any promotion that involves this type of marketing activity. BlueTriton
Brands does not endorse this activity and would never ask consumers to
participate in this type of promotion. If you are contacted by a scammer, please
reach out to local authorities, and report it to the Better Business Bureau’s
scam tracker: Find and Report a Scam | Better Business Bureau (bbb.org) and the
Internet Crime Complaint Center (IC3)  Internet Crime Complaint Center(IC3) |
Home Page. For information on how to avoid scams, please visit: BBB's Scam Tips

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PRIVACY POLICY


BLUETRITON BRANDS, INC. PRIVACY NOTICE AND POLICY

1.    Scope of this Policy

2.   What Personal Information Do We Collect and How Do We Collect It?

 * Information You Voluntarily Give Us
 * Information Collected Automatically
 * Information We Create or Generate
 * Information Obtained from Third Parties

3.   How Do We Use the Personal Information We Collect?

 * Provide Goods and Services
 * Personalization
 * Improve Our Services and Products, and Do Analysis
 * Market Our Products to You
 * Sweepstakes, Contests and Other Promotions
 * General Operations and Administration
 * Aggregate or De-Identify Personal Information

4.   To Whom do We Disclose the Personal Information We Collect?

 * Our Affiliates
 * Our Service Providers
 * Other Third Parties

5.    What Rights and Choices Do You Have Regarding Your Personal Information?

 * General Privacy Rights
 * Your California Privacy Rights

6.    Third-Party Websites and Services

7.    How Do We Protect Your Personal Information?

8.    How Long do We Retain Your Personal Information?

9.    Collection of Personal Information of Children

10.  Changes

11.  Contact Us


1. SCOPE OF THIS POLICY

Please read this privacy notice and policy (“Policy”) carefully to understand
our policies and practices regarding your personal information and how we will
treat it. This Policy applies to individuals who interact with BlueTriton
Brands, Inc. and Our services as consumers or members of the public (“you”).
This Policy explains how your personal information (which some jurisdictions may
refer to as “personal data”) is collected, used, and disclosed by BlueTriton
Brands, Inc., our affiliates and certain parties acting on our behalf
(collectively “BlueTriton”, “We”, Us”). It also tells you how you can access and
update your personal information, exercise certain rights, and make certain
choices about how your personal information is used.

This Policy covers both our online and offline data collection activities,
including personal information that We collect through our various channels such
as Our websites, telephone contacts and Customer Support, and apps (Our
"Services"), as well as third-party social media networks, consumer affairs,
certain third-party data sources, points of sale, and events where this policy
is provided to you. Please note that We might combine personal information from
different sources (website, offline event), including by combining personal
information that were originally collected by different BlueTriton entities or
BlueTriton partners. We also may combine data from third parties with data We
already have.

In some instances, if you do not provide personal information to Us, We may not
be able to provide you with certain goods and/or services. We will generally
indicate to you when this is the case, for example, by stating so on Our
registration forms or not enabling the process to continue without that
information.


2. WHAT PERSONAL INFORMATION DO WE COLLECT?

"personal information" is generally considered any information that can identify
you or that relates specifically to you. The personal information that We
collect about you depends on how you interact with Us and Our Services, what
requests you make from Us, and the context of our relationship.

Information You Give Us

When you interact with Us or the Services, you may provide certain personal
information to Us, including:

 * Identifiers, including certain data defined as personal information under the
   California Customer Records statute or as a protected classifications under
   California or federal law. This data includes:
   
   * Identification and Contact Data. Any data that specifically identifies you
     or allows us to contact you, such as your first name, middle name or
     initial, last name, nickname or alias, government-issued ID, postal
     address, e-mail address, social media network details, or phone number.
   
   * Account Login Data.Any data that is required to give you access to your
     specific account profile. Examples include your login ID/email address,
     screen name, password, and/or security question and answer.

 * Payment and Financial Data.Any data that We need in order to fulfil an order,
   or that you use to make a purchase, such as your debit or credit card details
   (cardholder name, card number, expiration date, etc.) or other forms of
   payment (if such are made available). We may also collect information in
   connection with your credit application, if any.

 * Demographic Data & Interests.Any data that describes or identifies your
   demographic or behavioral characteristics, including your date of birth, age
   or age range, gender, geographic location (e.g., ZIP code), favorite
   products, hobbies and interests, and household or lifestyle data.

 * Audio, Electronic, Visual and Similar Information. Any content that you
   create and share with Us on third-party social media networks or one of Our
   Services. Examples include photos, videos, personal stories, or other similar
   media or content. We may also record and collect information from you during
   conversations with Customer Service.

 * Commercial Information. Information relating to your use of the Services,
   including products or services purchased, obtained or considered and other
   purchasing or consuming history or tendencies.  

 * Sensitive Personal Information. Certain personal information that you provide
   might also be considered sensitive personal information under certain laws,
   including governmental IDs, social security number, account log-in
   information, health information, financial account information, precise
   geolocation data, and certain demographic information.

Information Collected Automatically

When you interact with Us or the Services, certain information is automatically
collected by the systems We use, including:

 * Data from Your Computer/Mobile Device/Browser.Data about the computer or
   device that you use to access Our Services, such as the Internet protocol
   (IP) address, and device and browser type, as well as other online
   identifiers. If you access Our Services via a mobile device such as a
   smartphone, the collected data will also include, where permitted, your
   phone’s unique device ID, advertising ID, and other similar mobile device
   data.

 * Internet or Other Similar Network Activity. As you navigate through and
   interact with Our Services or emails, We use automatic data collection
   technologies to collect certain data about your device(s) and your actions.
   This includes data such as which links you click on, which pages or content
   you view and for how long, and other similar data and statistics about your
   interactions, such as content response times, download errors, and length of
   visits to certain pages, as well as operating system type and web browser
   type and version. This data is captured using automated technologies such as
   cookies and web beacons and is also collected through the use of third-party
   tracking for analytics and advertising purposes (see "Do Not Track/Opt-Out of
   Targeted Advertising").

 * Audio, Electronic, Visual and Similar Information. We may visually record
   your interactions with Our Services, including your mouse clicks, movement,
   scrolling, and navigation through Our Services, including through the
   creation of heat maps.

 * Geolocation Data. Our systems record IP addresses, and that often provides
   your general location.

Information We Create or Generate

We may use certain personal information we collect to create or generate other
information, including:

 * Inferences. We may draw inferences from the data We collect from and about
   you to create a profile reflecting your preferences, characteristics, and
   behavior. We use this data for personalization and other general business
   purposes, such as internal or market research, developing  models for
   prospective customers, analytics, and security.

Information Obtained from Third Parties

We get personal information about you from other sources, including our
affiliates and business partners. We may obtain data from companies who compile
information about shoppers and their preferences, and we may also get
information from parties who we use for financial transaction, verification and
fraud prevention. Social media platforms may also give Us data about you. We may
get data about your interactions with our ads on third-party sites.  The
information that we obtain from third parties may be in any of the above
categories.


3. HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

Provide Goods and Services

We use certain personal information, including Identification, Account, Payment
and Financial, Commercial Information, Data From Your Device, Internet Activity
and Sensitive Personal Information to provide our goods and services to you,
including recording, processing, fulfilling, delivering and shipping your
orders; payment processing; and customer service.  We also use your personal
information to inform you about the status of your orders, correct addresses and
conduct identity verification and other fraud detection activities.  Specific
uses of this information include providing the products that you order,
providing access to your account, tracking orders and resolving issues,
responding to your requests and inquiries, and sending you updates regarding
products or services (including changes to this Notice and our other terms).

Personalization

We may use certain personal information, including Identification, Account,
Payment and Financial, Demographic Data, Commercial Information, Data From Your
Device, Electronic and Similar Information, Internet Activity, Geolocation Data
and Inferences  to (i) analyze your preferences and habits, (ii) anticipate your
needs based on our analysis of your profile, (iii) improve and personalize your
experience with Our Services, (iv) ensure that content from Our Services is
optimized for you and for your computer or device, (v) provide you with targeted
advertising and content, and (vi) allow you to participate in interactive
features, when you choose to do so. For example, We remember your login ID/email
address or screen name so that you can quickly login the next time you visit Our
Services or so that you can easily retrieve the items you previously placed in
your shopping cart. We may also show you specific BlueTriton content or
promotions that are tailored to your interests.

Improve Our Services and Products, and Do Analysis

We constantly strive to improve our offerings, and in order to do so, We analyze
interactions with Our Services and our marketing, reactions to our products,
order history, customer comments and Customer Support interactions, and user
behavior.  The information we use to do this may include any or all of the
categories of information that we collect.

The models we use to analyze this information include the range of tools
available to us from spreadsheets and databases to algorithmic models, and
technologies like artificial intelligence and machine learning.

Market Our Products to You

We may use your personal information to provide you with advertising and
marketing information about Our products and Services, as well as certain other
brands and products of others that we market or sell. The information that we
use for those purposes may include Identification, Account, Payment and
Financial, Demographic Data, Commercial Information, Data From Your Device,
Electronic and Similar Information, Internet Activity, Geolocation Data and
Inferences.  Our advertising may include targeted online advertising (see "Do
Not Track/Opt-Out of Targeted Advertising"). You can always opt out of receiving
advertising and marketing materials through your account, by following the
instructions for the specific message you receive, or through "Your Privacy
Choices" below:

Your Privacy Choices

Rewards Programs, Sweepstakes, Contests and Other Promotions

We have certain rewards programs and may also periodically offer promotions,
including coupons, sweepstakes or contests.  In order to participate in these
activities, we may collect and use certain personal information based on the
nature of the specific promotional activity, and there may be additional terms,
rules, requirements and notices associated with those promotions.

General Operations and Administration

In accordance with applicable laws, We use your personal information for other
general business purposes, such as maintaining your account, conducting audits,
financial calculations and tax reporting, administering our business and
operations, evaluating performance, evaluating and maintaining our systems,
security and fraud prevention and monitoring.  When and as appropriate, We may
also use personal information to exercise Our legal rights or perform our
obligations under applicable laws.  The information we use to do this may
include any or all of the categories of information that we collect.

Aggregate or De-Identify Personal Information

We may also use certain information that we have de-identified or aggregated (as
defined under applicable law) with other information so that it can no longer
identify, or be associated with, you.  Under applicable law, this information is
no longer personal information, and we can use and disclose the information for
any purposes, unless prohibited by applicable law.  The information we use to do
this may include any or all of the categories of information that we collect.


4. TO WHOM DO WE DISCLOSE THE PERSONAL INFORMATION WE COLLECT?

Our Affiliates

We may provide your personal information to our affiliates who process that
information for the delivery of our Services or for our business purposes as
described in this Policy.

Our Service Providers

We disclose your personal information to service providers who We engage to help
Us run our business (e.g., order management and fulfilment, payment processing,
fraud detection and identity verification, Customer Support, information
technology and computing support, customer relations management systems (CRM),
customer and consumer research, operations, managing marketing and promotions,
customer and consumer research, and similar activities). For the purposes of
fraud prevention, we may share your personal information with Forter, Inc., our
third-party provider of fraud screening services; please see Forter's privacy
policy.

Other Third Parties

We may also disclose personal information to certain other parties, including:

 * Credit reporting agencies/debt collectors (credit reporting agencies and debt
   collectors are external companies that We use to help Us to verify your
   creditworthiness (in particular for orders with invoice) or to collect
   outstanding invoices).
 * Advertising and marketing partners and agencies, including digital
   advertising networks, publishers, and technology providers.
 * Joint promotion partners, if any, as disclosed in the applicable joint
   promotion terms.
 * Other parties in connection with a corporate transaction, including a merger,
   acquisition, restructuring, or bankruptcy. Personal information may be
   disclosed in the context of due diligence relating to the transaction and/or
   to the successors to Our business or the applicable parts of it.
 * To law enforcement, governmental authorities or third parties when and as
   required by law; in response to legal proceedings; in response to a required
   from law enforcement; to protect Our rights, security, safety, or property,
   or those of other parties or the public; to enforce the terms of any
   agreement, including the terms of our Services.


5. WHAT RIGHTS AND CHOICES DO YOU HAVE REGARDING YOUR PERSONAL INFORMATION?

General Privacy Rights

You have certain rights with respect to your personal information under various
privacy and data protection laws. If you are a resident of California, you may
have additional rights (See "Your California Privacy Rights" ). The rights that
you have, and the process to exercise those rights, are as follows:

Right to Know/Access

This allows you to request that we tell you the information we have collected,
used, sold, or shared about you, as well as categories of personal information
or categories of sources from which your personal information was collected, the
purposes for which Personal Information was collected, and/or the specific
pieces of personal information collected about you during a particular time
period, as defined under appliable law.  You also have a right to request a
transportable copy of certain personal information.

Right of Correction

You have the right request the correction of any incomplete or inaccurate
personal information that we hold about you.

Right of Deletion (Erasure)

This enables you to ask us to delete all or certain elements of your personal
information where there is no valid business reason for us to continue to
process it or where we are required to erase your personal information to comply
with applicable law. Note, however, that there are exceptions to this right, and
we may not always be able to comply with your request of erasure for specific
reasons which will be notified to you, if applicable, once we review and process
your request. In addition, once deleted from our active systems, certain
information may remain in our archiving or backup systems until deleted in
accordance with our standard practices.

Do Not Track/Opt-Out of Targeted Advertising

The Services use several common tracking tools. These may include browser
cookies, web beacons, flash cookies, and similar technologies. Service providers
also use these tools on Our Services. and elsewhere on our behalf.  We also
share information about your use of Our Services with our social media,
advertising and analytics partners.

If Our system detects a Global Privacy Control (GPC) opt-out preference signal,
Our system will generally recognize and honor it. Because there is no standard
process to interpret other opt-out preference signals, Our system may not
recognize them.

You may also disable or block cookies and certain other tracking technologies
through certain software and browsers.  If you block or reject all cookies
through your browser some of the functionality of the Services may not work
properly.

For more information on cookies and tracking technologies, and to control those
uses, click on the Your Privacy Choices at the bottom of this page.

How to Exercise Your Rights

To exercise most of these rights, or if you have any questions or concerns, you
may submit this form with your request, or you may contact us at 844-887-3758 or
at dataprivacy@bluetriton.com.  For any personal information that is
automatically collected and is associated with your browser or device, you can
exercise your rights through Your Privacy Choices at the bottom of this page.
You are limited in the number of times that you can exercise specific rights in
any 12-month period.

For verification purposes, we may request any or all of the following: your
first and last name, account number, email address and any email address you may
have used when registering with BlueTriton, phone number associated with your
account, and a physical mailing/delivery address.

We will generally respond to your access or deletion request within 45 days of
receipt of your request, after proper verification, unless we need additional
time, in which case we will let you know.   The response we provide will also
explain the reasons we cannot comply with a request, if applicable.  

Right to Appeal

Under the laws of certain jurisdictions, you have the right to appeal our
decision not to act on your request to exercise certain of the rights described
above.  To appeal our decision if you are in an eligible jurisdiction, please
email us at:  dataprivacy@bluetriton.com the subject line "Individual Rights
Request Appeal."

Your California Privacy Rights

In addition to the rights set forth above under General Privacy Rights
California residents have certain rights with respect to personal information
under certain laws including the providers California Consumer Privacy Act and
the California Privacy Rights Act (as each may be amended or modified, from time
to time, and including any regulations promulgated thereunder) (collectively
referred to as the “CCPA”): 

Notice at Collection

At or before the time of collection of your personal information, you have a
right to notice of our privacy practices, as provided above in this Policy,
including the categories of personal information and sensitive information that
We collect, the purposes for which We collect and use that information, how long
the information is retained, and whether that information is sold or shared .

Financial Incentives

See our Notice of Financial Incentives.

Rights to Know, Correct and Delete

You have a right to request that We tell you the personal information we have
collected about you, the right to request additional information about how we
use, sell and share your personal information, the right to correct inaccurate
personal information that we have about you, and the right to request the
deletion of your personal information.

Note that we have provided much of this information in this Privacy Policy. You
also have rights to request that we correct inaccurate personal information and
that we delete personal information under certain circumstances, subject to a
number of exceptions. Those rights are described above under "General Privacy
Rights", and to exercise those rights, see "How to Exercise Your Rights" .

Do Not Sell or Share My Personal Information

If you are a California resident, you have a right to opt-out from the “sale” or
“sharing” (as those terms are defined under the CCPA) of your personal
information with third parties. To exercise this right, click on "Your Privacy
Choices" below:

Your Privacy Choices

or at the bottom of the page, or in the "About" section in our app. We do not
knowingly “sell” or “share” the personal information of minors under 16 years
old.

Authorized Agents

In certain instances, you may designate an authorized agent to exercise your
rights under this section. The agent may submit the requests as in this
section.  We have verification processes that we will need to follow, and as
part of our verification process, we may request that the agent provide proof
concerning their status as an authorized agent and that you verify your identity
and confirm that you provided the agent permission to submit the request.

Non-Discrimination

We will not unlawfully discriminate nor retaliate against you for exercising the
rights under this section.

Right to Limit the Use and Disclosure of Sensitive Personal Information

You have a right to limit Our use of sensitive personal information for any
purposes other than to provide the Services or goods that you request or as
otherwise permitted by law. To exercise this right, see "How to Exercise Your
Rights".

“Shine the Light” Law Rights

Under the California “Shine the Light” law, California residents may opt out of
Our sharing their personal information with certain parties for their direct
marketing purposes. In order to exercise this right, see "How to Exercise Your
Rights"  and include the subject line “Shine the Light Opt-Out” in the subject
line and your name and in the body of the message.


6. THIRD-PARTY WEBSITES AND SERVICES

The Services may include links to third-party websites or apps, including social
media platforms. Those third-party websites and services are not Services
operated or controlled by Us. This Policy does not apply to, and We do not
control and are not responsible for, the privacy practices of those third-party
websites or services. Please read their privacy policies carefully, since they
have their own practices and policies, and they may collect and use your
personal information in very different ways that We do.

Our Services may also include third-party content that collects data. This
includes data collected by cookies, pixels, or other tracking tools, as further
described above under "Do Not Track/Opt-Out of Targeted Advertising".


7. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We use reasonable and appropriate security measures to protect your personal
information.  No method of transmitting or storing data is completely secure,
and despite our efforts to protect your personal information, We cannot
guarantee the security of your personal information.

It is important that you also play a role in keeping your personal information
safe and secure. When signing up for an online account, please be sure to choose
an account password that would be difficult for others to guess and never reveal
your password to anyone else – generally meaning a unique, long and complex
password. You are responsible for keeping this password confidential and for any
use of your account. If you use a shared or public computer or other device,
never choose to have your login ID/email address or password remembered and make
sure to log out of your account every time you leave the computer or device. You
should also make use of any privacy settings or controls We provide you in our
Services.


8. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

We keep personal information as long as it is necessary, relevant, or permitted
for the purposes described in this Policy. We also keep personal information
when and as otherwise required by law. 

This might mean that We keep some or all of your personal information even after
you close your account with Us or otherwise end your relationship with Us, even
if you exercise your deletion rights. When determining how long to retain your
personal information, we take into account a number of factors, including the
length and nature of our business relationship and the Services you obtain, the
applicable statute(s) of limitation, and whether we are subject to any legal
obligations relating to your personal information.  We also might de-identify
certain personal information rather than deleting it.


9. COLLECTION OF PERSONAL INFORMATION OF CHILDREN

Our Services are intended for a general audience, and are not directed at
children under the age of 13. We do not knowingly solicit or collect personal
information from children below the age of 13. If you are a parent or legal
guardian and think that your child under 13 has given Us data, you can contact
Us in writing or by email as provided below under the section titled Contact Us.
Please mark your inquiries “COPPA Information Request.” We do not knowingly sell
the personal information of minors under the age of 16 without affirmative
authorization.


10. CHANGES TO THIS POLICY

We are always improving our products and services, and we may change how we
collect, use or disclose your personal information. In addition, the laws
regarding personal information and privacy change frequently. Because of these
changes in our practices and applicable laws, we periodically update this
Privacy Policy.

When we make changes to this Policy, we will post any changes on this page so
please check back frequently.  If we make material changes, if we have your
contact information, we will notify you prior to the changes taking effect, and
we will also post a notice through the Services.

Any use of our Services after we post the updated Policy will be subject to that
updated Policy.


11. CONTACT US

To contact us about this Policy and/or our privacy practices, please contact Us
at dataprivacy@bluetriton.com, 900 Long Ridge Road, Building 2, Stamford, CT
06902, or 844-887-3758.

Last Updated: June 9, 2023

 

 

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