Updated September 15, 2022
This Privacy Statement describes how WD-40 Company and its affiliates (collectively “WD-40,” “we,” and “us”) collect, use and disclose personal information we collect when you visit or use our websites or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media, participate in our sweepstakes or contests or otherwise interact with us (collectively, our “Services”). By using our Sites and Services, you consent to the collection, processing, use, and disclosure of your personal information in accordance with this Privacy Statement.
Click here to download a copy of this Privacy Statement.
This Privacy Statement does not apply to information collected in connection with employment from job applicants, current and former employees and, where applicable, to current and former workers and contractors who provide services to us.
We do not collect or process personal information pertaining to your racial or ethnic origin, political opinions, religion or philosophical beliefs, health or medical condition, criminal background, trade union membership, genetic or biometric data, sexual life or orientation (referred to as “sensitive personal information”). We ask that you not send nor disclose, any sensitive personal information to us. We may, however, ask you to disclose to us information related to your health or medical condition when necessary to analyze and address incidents with our products or packaging. Furthermore, we will process such information if you communicate it to our agents during a call or you are voluntarily expressing consent through a communication or any other means.
We use your personal information for the following purposes:
Legal Basis for Processing: Our legitimate interests to handle, adequately and in a timely manner, customers’ inquiries, complaints and suggestions regarding the Sites and Services.
Legal Basis for Processing: Our legitimate interests to improve our Sites and Services and evaluate the performance of our employees and contractors and your consent.
Legal Basis for Processing: Your consent
Legal basis for Processing: The processing of your personal information for this purpose is based on performance of the relevant promotion terms and conditions and your consent.
Legal Basis for Processing: Our legitimate interests to improve our Sites and Services and evaluate the performance of our employees and contractors.
Legal Basis for Processing: Our legitimate interests to protect our organization and to comply with our legal obligations.
We will share personal information in the below circumstances or as otherwise described in this Privacy Statement.
Service Providers: We may share personal information with vendors and service providers who support the operation of the Services, the Sites, and our business and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, email delivery, marketing, insurance, storage and warehouse services, customer support services, and the administration, judging and prize fulfillment aspects of promotions, competitions and sweepstakes). In some cases, the vendor or service provider may directly collect the information from you on our behalf.
Affiliates: We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.
Marketing/Analytics/Advertising Partners: We may share personal information with third-party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails and advertisements.
Professional Advisors: We may share information with professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Government Entities: We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; corporate registries; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.
With Your Consent or At Your Direction. We may share information with third parties whenever you consent to or direct such sharing.
Other Reasons: We may share information for other reasons we may describe to you.
You can opt out of marketing or advertising emails and newsletters by using the “unsubscribe” link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified in the Contact Us section of this Privacy Statement. Once we process your request, we will cease using the information for such purposes at no charge to you.
We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
Do Not Track Signals: Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.
Google Analytics: We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.
Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
We keep your personal information for as long as necessary to provide you with the Services, for legitimate and essential business purposes, such as making data-driven business decisions, complying with our legal obligations, and resolving disputes. Personal information is not kept for longer than is necessary for the purpose for which it was collected, held, and processed. The retention periods for personal information varies depending on whether that data is held as part of a legally required business record.
We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13, we will remove their personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to email@example.com.
To change or update the information we hold and which relates to you please contact us, using the contact details at section 11.
If you have questions or concerns regarding our privacy practices or this Privacy Statement, you may contact by writing or emailing us at the address below:
Address: 9715 Businesspark Avenue, San Diego, CA 92131
We may revise or update this Privacy Statement from time to time. The last updated date above indicates the most recent date of revision. The updated Privacy Statement will be posted on our Sites. Your continued use of the Services or Sites after we post a revised Privacy Statement signifies your acceptance of the revised Privacy Statement.
For residents of California, the following additional provisions apply to you.
Shine The Light: If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please send an email to firstname.lastname@example.org and include “CA Shine the Light” in the subject line of your email.
California Consumer Privacy Act (CCPA) Disclosures:
Categories and sources of personal information we collect: In the preceding 12 months, we have collected the following categories of personal information: contact information, identifiers, social media profiles, user generated content, commercial information, geolocation data, usage data, audio/visual data and inferences. For details about the data points we collect and the categories of sources of such collection, please see section 1 above.
Purposes for which we use personal information: We collect personal information for the business and commercial purposes described in section 2 above.
Disclosure for a business purpose: In the preceding 12 months, we have disclosed the following categories of personal information for the business purposes set forth in section 3 above to the following categories of recipients:
|Category of Personal Information||Categories of Recipients|
|service providers, affiliates, professional advisors, government entities|
|service providers, affiliates, professional advisors, marketing/analytics/advertising partners|
|Social Media Profiles
|service providers, affiliates, professional advisors, marketing/analytics/advertising partners|
|User Generated Content||service providers, affiliates, professional advisors, marketing/analytics/advertising partners|
|Commercial Information||service providers, affiliates, professional advisors, government entities, marketing/analytics/advertising partners|
|Usage Data||service providers, affiliates,
|service providers, affiliates,
|Audio/Visual Data||service providers, affiliates
|Inferences||service providers, affiliates
For a more expansive description of the categories of recipients, please see section 3 above.
Your Rights Under the CCPA
Subject to certain exceptions, the CCPA affords California consumers the following rights:
You have a right to request what personal information we have collected, used, disclosed and sold about you in the preceding 12 months. You can also request the specific pieces of personal information we have collected about you. You can also request the following categories of information:
You can also request that we delete your personal information. We may not delete all of your personal information if one of the exceptions to the CCPA applies. Please note that if we delete your personal information, the Services provided may not maintain the same functionality. For example, your previous opt-out requests will not be saved and saved preferences and information will no longer be available.
You have a right to opt out of the sale of your personal information. The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. While we do not sell personal information for monetary value, we may disclose personal information to third parties, such as marketing/analytics/advertising partners, in such a way that may be considered a “sale” of personal information under the CCPA. We do not sell personal information of minors who we know are under 16 years of age.
You have a right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.
Exercising Your Rights Under the CCPA
To exercise any of your CCPA rights, please click or call us at 1-877-906-1824. For all requests, you must provide us with your name, email address, phone number, and mailing address. Failure to provide all of the foregoing information will prevent us from processing your request.
Further, in order to verify your identity, we will provide a verification form to you at your email address. Please be aware that you must complete the verification form and submit it to us in order for us to match that information to the information we have in our systems and process your request. Additionally, some requests may be subject to additional identity verification procedure. In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at email@example.com.
Other Consumer Rights Information: Under California Civil Code Section 1789.3, we are required to provide California residents with the following information:
European Economic Area (EEA), the United Kingdom, and Switzerland
For residents of the European Economic Area (EEA), the United Kingdom, and Switzerland, the following additional provisions apply to you.
Controller: The controller of your personal information is: WD-40 Company Limited
Disclosure and Cross-Border Transfer: Personal information that is shared with affiliates and third parties as described in this Privacy Statement is done pursuant to contracts that include the requisite protections under the GDPR or UK GDPR, as applicable. We are a global company, and your personal information will be shared among us and transferred outside of your country of residence. By using the Sites or Services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own and that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence. In accordance with GDPR and UK GDPR, personal information that is transferred outside of the European Economic Area is conducted in accordance with compliant arrangements such as data transfer agreements that contain standard contractual clauses adopted by the European Commission that provide safeguards for such transfers or legally recognized certifications.
Your Rights Over Your Personal Information: You have the right to request that we:
To exercise any of these rights please contact us at firstname.lastname@example.org.
You must use “GDPR Request” in the subject line of your email or letter. For all requests, you must provide us with your name, email address, phone number, and mailing address. Failure to provide all of the foregoing information will prevent us from processing your request.
Further, in order to verify your identity, we will provide a verification form to you at your email address. Please be aware that you must complete the verification form and submit it to us in order for us to match that information to the information we have in our systems and process your request.
We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any matters related to the use and disclosure of your personal information.
For residents of Mexico, the following additional provisions apply to you.
Data Controller: Your data controller is WD-40 Co. Mexico, S. de R.L. de C.V.
Use of Your Personal Data: Personal data that we collect is used only for the purposes contained in section 1 of this Privacy Statement or as stated within materials you receive.
Consent to Processing: In accordance with the Federal Law on Protection of Personal Data Held by Private Parties and its accompanying regulations, you consent to the processing of your personal data in accordance with the provisions of this Privacy Statement unless you express your objection in the manner provided for under the Your Rights section of this Privacy Statement. We may process financial or asset information to provide you with our products and services for the purpose of fulfilling obligations under a legal relationship between you and us.
Your Rights: You have five (5) days after this Privacy Statement has been brought to your attention to refuse to allow the processing of your personal information for purposes that are different than those that are necessary pursuant to a legal relationship between you and us; otherwise, you are deemed to have consented to such processing. You also have the right to access your personal information; to rectify such information when it is inaccurate or incomplete; to cancel or delete your personal information; to oppose the use your information for a specific purpose; or to revoke consent previously granted to the extent permitted by law. If you cancel or revoke our ability to use certain personal information, we may not be able to provide certain goods and services to you.
To exercise any of the rights described above, please email us at email@example.com. You must include in the email (a) your full name; (b) your contact information, including your mailing address, email address, and telephone number; (c) the right you wish to exercise; (d) proof of your identity or your legal representative; and (e) any other information, item or document that will assist us in locating your personal data.
We will respond to your request within twenty (20) days after receipt of your request and verification of your identity or any longer period permitted by law. We may contact you (i) to request additional information from you if we are not able to verify your identity from the information you provide in your email request; (ii) to inform you of the timeframe within which you will receive a response to your request; (iii) to provide you with directions on how you must submit your request, including the forms you can use to submit your application, if any, and; (iv) to inform you about how we will deliver to you the information you requested (which usually would be copies of documents or information).
Data Transfers: We may transfer your personal data as provided for in section 3 of this Privacy Statement. Such transfer is to third parties who are necessary for providing our goods and Services to you, to our affiliates, or third parties that are necessary pursuant to our legal relationship with you or to protect our legal rights. We will seek your consent when required if such transfer is not for the stated purposes identified in this Privacy Statement.