1. Important information and who we are
2. The data we collect about you
3. How we collect your data
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
ZAH Group, Inc. and its subsidiaries (collectively, “ZAH Group”, “we” or “us”), including Klein Tools, Inc., are committed to protecting your privacy and ensuring the highest level of security for your personal data.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed (anonymous data).
· Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you have used to access this website.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use our website, products and services.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
In cases where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In such cases, we may have to cancel a product or service you have with us, but we will notify you at the time when this occurs.
3. How we collect your data
· Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites that are employing our cookies.
· Third parties or publicly available sources. We will receive personal data about you from analytics providers such as Google, which is based in the United States.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a lawful basis for the processing of your personal data, although we will obtain your consent before sending third party direct marketing communications to you via email or text messages. You have the right to withdraw your consent to the receipt of marketing materials at any time by contacting us.
Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, when more than one ground has been set out in the table below.
Type of data
Lawful basis for the processing, including the basis of a legitimate interest
To manage our relationship with you, which may include asking you to leave a review or take a survey.
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting)
Necessary for our legitimate interests (for running our business, as well as for the provision of administration and IT services, network security, preventing fraud and in the context of a business reorganisation or group restructuring)
Necessary to comply with a legal obligation
To deliver relevant website content and measure or understand the effectiveness of our website content
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation about how the processing for the new purpose is compatible with the original purpose, please contact us.
· Internal Third Parties, as defined in the Glossary.
· External Third Parties, as defined in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the ZAH Group, which means your personal information may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal information as your home country. In addition, the external third parties that may store and process your personal information are based in countries around the world, including in countries that may not offer the same level of protection for your personal information as your home country.
When we transfer personal information internationally, we put in place safeguards on that information in accordance with the applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation). If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact our Privacy Team.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to employees, agents, contractors and other third parties who need to know for business purposes. They will only process your personal data according to our instructions and they are subject to the duty of confidentiality.
We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from the unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without providing further notice to you.
You may have the right under European and other laws to access your personal information, and to ask us to rectify, erase and restrict the use of your personal information. You may also have the right to object to your personal information being used, to ask for a transfer of the personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.
We will honour your rights under the applicable data protection laws. You have the following rights under European laws, and you may have similar rights under the laws of other countries.
· Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
· Request the erasure of your personal data. This enables you to ask us to delete or remove personal data when there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data when you have successfully exercised your right to object to its processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to the processing of your personal data when we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to the processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
o You want us to establish the data's accuracy.
o Our use of the data is unlawful, but you do not want us to erase it.
o You need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend a legal claim.
o You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to the automated information which you initially provided consent for us to use, or where we have used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time when you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that the personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, in order to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Some laws require us to explain our lawful reason for processing your personal information. We process the personal information about you on the basis that it is:
· necessary for the performance of a contract: in cases where we have a contract with you, we will process your personal information in order to fulfill that contract (e.g. to provide you with goods or services)
· in our or a third party’s legitimate interests: details of those legitimate interests are set out in more detail below (e.g. the provision of goods or services that we are contractually obliged by a third party to deliver to you)
· where you give us your consent: we only ask for your consent in relation to specific uses of your personal information when we need to and, if we need it, we will collect it separately and make it clear that we are asking for your consent
· for compliance with a legal obligation (e.g. to respond to a court order or a regulator)
Legitimate interest means the interest of our business in conducting and managing our business, to enable us to give you the best service/product and the best and most secure experience. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent, or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you with respect to specific activities by contacting us.
Performance of a contract means the processing of your data in a case where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Other companies, agents or contractors used by the ZAH Group to perform services on our behalf, or to assist us with the provision of the Company’s services and products to you. Your personal data may be shared with the following categories of service providers, acting as processors or joint controllers of your personal data:
· infrastructure and IT service providers, including cloud service providers;
· marketing, advertising and communications agencies;
· online payment and fraud prevention service providers;
· delivery/logistics service providers (for the delivery of products bought online);
· external auditors and advisers (e.g. social media consultation providers);
· providers of services related to some enhanced online features such as customer reviews;
· cookie analytics providers;
· online advertisers; and
· providers of website testing/analytics services.
In addition, external third parties include legal or regulatory authorities, acting as processors or joint controllers, who may require the reporting of processing activities in certain circumstances.