Last Updated: August 10, 2023

Effective Date: August 10, 2023

This Privacy Policy (“Policy”) describes how Sensio Inc. dba Made By Gather (“Sensio,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information through the recall.sensiobrands.com website (the “Site”), as well as the rights and choices individuals have regarding such personal information. We also provide additional information for California residents (see here).

By using our Site, you agree that your personal information will be handled as described in this Policy. Your use of our Site and any dispute over privacy, is subject to this Policy and our Terms of Use, available here, including their applicable terms governing limitations on damages and the resolution of disputes.

Contents

1. Scope of this Policy
2. Personal Information We Collect
3. How We May Use Personal Information
4. How We May Disclose Personal Information
5. Children’s Information
6. External Links and Features
7. Security
8. California Privacy Rights
9. Changes to this Policy
10. Contact Us

 

1. Scope of this Policy

Except as otherwise described below, this Policy applies to the personal information Sensio collects and processes related to:

• Visitors to the Site, recall.sensiobrands.com ;
• Individuals who use the Site to email us, call us, submit recall requests, or otherwise communicate with us relating to recalls via the Site;

Other Notices. Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices. For example, this Policy does not apply if you visit any of Sensio’s other websites that post a different privacy policy.

2. Personal Information We Collect

As further described below, we collect personal information directly from you.

Personal Information We Collect Directly From You. While the personal information we collect varies depending upon your use of our Site and our interactions with you, in general, we may collect the following Personal Information directly from you:

• Contact Information. When you contact us via the Site, we collect your name/alias, email address, phone number, the nature of your recall, and any other information you choose to provide. We may also collect information related to your job title, company name, business email, and business phone number.
• Recalled Product Information. When submitting a recall form via the Site, we also collect information regarding the recalled product you are returning, such as the model or item number, images you choose to upload (including images of receipts), date of purchase (optional), location of purchase, whether injury or death was caused while using the product, and proof of purchase.
• Communications and Interactions. When you email, call, or otherwise communicate with us or with members of our team, we collect and maintain a record of your contact details, communications, and our responses.

3. How We May Use Personal Information

We collect, use, disclose and otherwise process the personal information we collect about you for the following purposes:

• Processing Recalls and Issuing Refunds. To allow us to manage the recall process, including determining your eligibility for a refund, and, if eligible, issuing you a refund for the product. 
• Shipping. To issue you shipping labels for you to return the recalled items.
• Troubleshooting and Support. To provide troubleshooting and technical or customer support.
• Communicate With You. To respond to your inquiries, and send you administrative information, for example, information regarding the recall and changes to our terms, conditions, and policies.
• Security and Protection of Rights. To protect our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use. 
• Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

4. How We May Disclose Personal Information

We may disclose the personal information we collect for the purposes described above and as follows:

• To the U.S. Consumer Product Safety Commission (CPSC). We may be required by law to disclose information relating to the recalled products to the CPSC, which may include any information submitted via the Site.
• Affiliates, Subsidiaries, and Business Partners. We may disclose the personal information we collect to our corporate affiliates and subsidiaries as needed to process recalls and for other purposes described in this Policy. 
• Vendors and Service Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf in support of the recall process, such as shipping, IT and website hosting, customer support, data storage, auditors, consultants, and legal counsel.

We may also disclose your personal information in the following circumstances:

• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transactions such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. Where we believe doing so is necessary to protect us, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Site, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and act in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Site with third parties for quality control, analytics, research, development, and other purposes. 
• Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.

5. Children’s Information

Our Site is not designed for children, and we do not knowingly collect personal information from children under the age of 13. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

6. External Links and Features

Our Site may contain links to third-party websites or features. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features.

7. Security

We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

8. California Privacy Rights

This section of the Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020, and its implementing regulations (the “CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices. 

This section applies to “personal information”, as defined in the CCPA, that we collect in connection with the recall described on the recall.sensiobrands.com website (the “Site”), whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA.

Personal Information We Collect. Depending on how you use the Site, we may collect the following categories of personal information (and have collected in the prior 12 months):

Identifiers. Such as name, alias, email, phone number, address, unique customer ID, and similar identifiers.

Commercial Information. Such as records of personal property, products or services purchased, date of purchase (optional), and location of purchase.

• Audio, Electronic, Visual, or Similar Information. Such as information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line.

Sources of Personal Information. We generally collect or receive personal information from the following categories of sources:

• Directly from you; 
• Our affiliates and subsidiaries;
• Our business partners;
• Insurance carriers;
• Government agencies.

Purposes for Collecting and Disclosing Personal Information. As described in the “How We May Use Personal Information” section above, in general, we collect and otherwise process the personal information we collect for the following business or commercial purposes:

• Processing recalls and issuing refunds;
• Shipping;
• Troubleshooting and support;
• Communicating with you;
• Security and protection of rights; 
• Compliance and legal process; 
• Auditing, reporting, and other internal operations; and
• General business and operational support.

Retention of Personal Information. We retain your personal information for as long as needed or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

Disclosure of Personal Information to Third Parties and Other Recipients. The categories of personal information we have disclosed for a business purpose in the preceding twelve (12) months include: identifiers, customer records, and commercial information. The categories of third parties and other recipients to whom we may disclose personal information for a business purpose may include: affiliates, subsidiaries, and business partners, vendors and service providers, and government entities.

Sales and Sharing of Personal Information. We do not sell or share the personal information collected through this Site or other personal information we collect in connection with a recall, and we do not sell or share personal information about individuals we know are under age 16.

Your CCPA Rights. The CCPA provides California residents with the following rights regarding their personal information, subject to certain exceptions: 

Right to Know/Access. You have the right to request:

• The categories or personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purposes for collecting, selling, or sharing personal information; (we do not sell or share personal data covered by this Policy);
• The categories of third parties to whom we have disclosed personal information; and
• A copy of the specific pieces of personal information we have collected about you.

Right to Correct. You have the right to request that we correct inaccuracies in your personal information.

Right to Delete. You have the right to request we delete your personal information.

Right to Opt-Out of Sales and Sharing. We do not sell or share the personal information we collect that is subject to this Policy, so there is no need to exercise this right.

Right to Limit Use. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the CCPA.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your CCPA Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:

• Calling us at 1-855-647-3125
• Email us at recall@sensiobrands.com

Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your full name, email address, and any order number you may have. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Do Not Track. Currently, our Site does not recognize “Do-Not-Track” requests (but note that our Site does not sell or share personal information). You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

9. Changes to this Policy

The Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we have previously collected from you, we will endeavor to provide you with notice, such as by posting prominent notice on our Site.

10. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at any of the following methods:

• Calling us at 1-855-647-3125
• Email us at recall@sensiobrands.com