Last Updated: May 31, 2022 Effective Date: June 1, 2022
Lippert Components, Inc. and its family of brands are committed to protecting your privacy. We strive to protect the privacy of Personal Information in our custody, keeping with the access and privacy provisions of applicable legislation. “Personal Information” as used in this Privacy Notice means any information relating to an identified or identifiable individual, or as defined under applicable law.
This Privacy Notice (“Privacy Notice”) governs how we collect, use, share and protect your Personal Information. It applies to your access to and use of any websites or online services operated and controlled by Lippert (collectively the “Lippert Services”) and any data collection we perform offline.
Before accessing, using, or interacting with our services, you should carefully review all terms of this Privacy Notice. This Privacy Notice applies to your information as collected, used or disclosed by us. It does not apply to third-party websites, applications, or services. If any term in this Privacy Notice is unacceptable to you, please do not use our services or provide any Personal Information to us.
Please use the following links to navigate to sections of interest:
Information Collection & Use
Your Choices and Rights Regarding the Information We Have Collected About You
Transfer And Storage Of Your Information
Personal Information of Minors
Additional Information for California Residents Changes to Our Privacy Notice
References in this Privacy Notice to “we,” “our” or “us” are references to the LCI brand or entity that is responsible for the collection and use of your personal data, which is generally the brand or entity that obtains your personal data in the respective case and/or with which you do business. This entity also is referred to as the data controller.
We collect information about you through various means, including when you directly provide your Personal Information to us and when we automatically collect information about you when you access, use, or interact with the Lippert Services.
We use this information for a variety of different reasons, as further set out below, including to measure use of and improve our services and to tailor our services to you. You are not required to provide your Personal Information; however, if you choose to withhold certain Personal Information, we may not be able to provide you with certain services, functions or features.
The categories of information we may collect include:
|Context of Collection||Types of Data Collected||Purpose and/or Legal Basis for Collection|
|Account Registration||We may require you to register for an account in order to use certain services. We do not require you to register to use all features of the Lippert Services. However, if you do register for account, you will gain access to those areas and features of the Lippert Services that require registration. We will collect certain information about you in connection with your registration for the account, which includes your first name and last name, email address, mailing address, and phone number, and other information such as a password, username, and RV Vehicle Identification Number (VIN), hull identification number, make, and model.||We have a legitimate interest in providing account related functionalities to our users.|
|Business Partner & Client Information||We collect the name, address and contact information, of our current and prospective business partners and clients, as well as their employees with whom we may interact. This includes registered and prospective registered dealers and their employees.||We have a legitimate interest in contacting our business partners and clients and communicating with them concerning normal business administration such as projects, services, and billing.|
|Career Information||If you choose to apply online with us, we may collect Personal Information from you such as your resume, Curriculum Vitae (“CV”), physical address, work experience, e-mail address and other contact details, and work preferences.||We use this information in anticipation of performance of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your Personal Information to have efficient staffing and work force operations.|
|Device Information||We may collect and use information about your device, such as the name and type of the device, the operating software, the device’s location and your devices unique identifier, such as a universally unique identifier (“UUID”).||We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.|
|Distance Information||We provide certain services based on your geographic location, which we may collect through your use of the Lippert Services. For example, when you use or interact with the Lippert Services, we may access, collect, monitor and/or remotely store data about your location, which may include your address, zip code, GPS coordinates, or similar information regarding the status and location of your computer, mobile device, or other devices used to access the Lippert Services (“Location Information”). We may also determine location by using other data from your device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device, or your IP address. We may also use Location Information via third party APIs such as Apple’s Region Monitoring or Google Geofence API to help provide intelligent notifications to our users regarding updates or actions they should take relating to the Lippert Services.||
Generally, our use of distance information is based upon your consent. When you use the Lippert Services, you will receive prior notice and the opportunity to consent before your location will be used or shared.
In some cases, our use of this information is based on our legitimate interest in providing tailored services to individuals in certain regions and to maintain, improve and customize the services that we offer.
|Feedback/Support||You may provide your Personal Information to us in the context of a support request. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Please do not submit any confidential, sensitive or other information to us via a support submission that you do not wish for Lippert or our Service Providers (as defined below) to have access to or use in the future.||We have a legitimate interest in receiving and acting upon your feedback or support issues. In some cases, we may also collect this information to allow us to perform our contract with you.|
|Information Collected through Your Use of Our Apps||We maintain several mobile apps (“Apps”) as part of the Lippert Services which allow users to remotely control and monitor many recreational vehicle, boating and other systems from a smartphone or in-unit touchscreen unit, such as RV awnings, boat shade systems, slides, jacks, and lifts. When you use these features of the Apps, we collect certain information about the use and the devices controlling the use. This information can include information gathered from and about your devices, such as the hardware you’re using, associated devices, detailed information about your and the app features that you use, geolocation information (please refer to the Distance Information section above for more details about our collection of this type of Personal Information), and information you input into the devices such as your name, contact information, email address, and vehicle identification number or hull identification number.||We have a legitimate interest in identifying unique users, and in understanding how users interact with us on their associated devices. We also have a legitimate interest in improving our apps and control platforms and in detecting and preventing fraud.|
|Information Collected through Your Use of RV Tech Bridge®||Our RV Tech Bridge® service (part of the Lippert Services) allows recreational vehicle owners to connect directly with Lippert service technicians. Owners have the option to connect with RV Tech Bridge® technicians through chat, phone calls and video calls. If you sign up for and/or use the RV Tech Bridge® service, we will collect information such as your contact details, payment details, vehicle information (such as make, model, and VIN number), and, in some cases, location details (please refer to the Distance Information section above for more details about our collection of this type of Personal Information). We also collect any information that you provide to us when you connect with us using the methods described above, including, but not limited to information that you share with us through the chat feature, audio data, visual images, or video data that you upload or transmit to us through the RV Tech Bridge® service.||We collect this information to perform our contract with you and to provide you with the RV Tech Bridge® services you request. We also have a legitimate interest in understanding how users utilize the RV Tech Bridge and improving the services offered.|
|Mailing Lists, Blogs & Other Communications||If you email us, subscribe to our newsletters mailing lists, or blogs, we collect your name, and email address. If you receive an email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.||We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in responding to your requests, providing the requested products or communications, providing notifications or other correspondences to you and understanding how you interact with our communications to you.|
|Payment & Order Information||We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order.||We use your information to perform our contract to provide you with products or services.|
|Service Appointment Information||We may collect information such as your name, boat, vehicle or RV make, model, year, license plate, Vehicle/Hull Identification Numbers or other identifying information about your vehicle or equipment.||We collect this information to perform our contract with you and also have a legitimate interest in fulfilling the services you request.|
|Social Media||We may use social media plug-ins to enable you to easily share information on the Lippert Services with others. These plug-ins may include those from companies like Twitter, Facebook, Instagram, YouTube, and LinkedIn. When you visit the Lippert Services, the operators of the social media plug-ins on the Lippert Services place cookies on your computer that enable them to recognize you on websites belonging to them and their affiliates and partners after you have visited the Lippert Services, or that enable them to add the information collected from your visit to our Site with your prior activity on those websites. The social media plug-ins collect this information about users whether they specifically interact with the plug-in or not, and they may enable social media companies to share information about your web-browsing navigational information with some of their other users. This information may include your preferences about how to contact you or further develop a business or professional relationship with you, your product preferences, languages, marketing preferences, and some demographic data. We do not control what information is collected by the social media plug-ins or the information practices adopted by those social media companies. For more information about social plug-ins from social media websites, you should refer to those companies’ privacy and data sharing statements.||Where required by law, we base the collection of this information on your consent. We also have a legitimate interest in learning about our customers’ interests and in tailoring and improving our services.|
|Surveys||When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy notice applies to the collection, use, and disclosure of your information.||We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.|
|Web Forms||We may use forms to request certain Personal Information from you in order to perform certain Lippert Services, such as your location to assist you in locating our products, and your contact information (name, phone number) and any information you voluntarily provide in order to assist with contacts or service requests. We also use forms to receive Personal Information from you, for example, when you register for an event with us. This includes your name, email address and any other information you voluntarily provide. It may also include your company name and job title, physical address and your years of experience.||We have a legitimate interest in responding to your requests, providing any requested information or services to you, and providing notifications or other correspondences to you.|
|Website Interaction Analytics||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Web logs||We may collect certain log file information related to your use of the Lippert Services, such as your IP address, browser type, access times, domain names, operating system, the referring web page(s), pages visited, the amount of time spent on certain pages or using the Lippert Services, your location, your mobile carrier, information about your device (including device and application types, network connections, names, and IDs), search terms, and cookie information (“Log File Data”). We receive this Log File Data automatically when you interact with the Lippert Services, for example, when you use the Lippert Services, or interact with our devices, products, or communications we send to you. We use this Log File Data to provide, understand, and improve the Lippert Services, and to customize the content we show you. We may correlate this data with other information that we collect about you via the Lippert Services, including Personal Information and your interactions with the Lippert Services.||We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, registered dealers, independent service technicians, other business partners, our affiliates, or publicly available sources.
We share Personal Information as set forth below:
1.Service Providers: Lippert Components, Inc. works with various organizations, and individuals to help provide the Lippert Services to you ("Service Providers"), such as hosting companies, shipment, payment processing companies and companies providing analytics information, like Google Analytics. We may share your information with our Service Providers for the purpose of providing our services. The information we share to our Service Providers may include both information you provide to us and information we collect about you, including Personal Information and information from data collection tools like analytics information, Log File Data, UUID information, vehicle information, device information, payment information, and Location Information. We take reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on our behalf. These entities are restricted by written agreements from using this data in any way other than to provide services for us, or for the collaboration in which they and we are engaged (for example, some of our products are developed and marketed through agreements with other companies). Service Providers, furthermore, are prohibited from selling your Personal Information.
2.Third Party Marketers and Advertisers: We may share certain information about you to third party marketers and advertisers, including the original equipment manufacturer who produced your vehicle and providers of equipment and/or services for the vehicles and products you have purchased. We allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the non-personally-identifiable attributes we have collected to select the appropriate audience for those advertisements. When you click on or otherwise interact with an advertisement, there is a possibility that the advertiser may place a cookie in your browser and that your attributes meet the criteria the advertiser selected.
3.Affiliates and Business Transactions: Lippert Components, Inc. may share your Personal Information with its corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). LCI may also purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including Personal Information, may be among assets sold or transferred as part of a Business Transaction.
5.Original Equipment Manufacturers (“OEMs”): We may share your Personal Information with third parties including OEMs who may use the information to improve their products. We will only share information with OEMs that are contractually required to protect your data, not permitted to sell your Personal Information and use it for the limited purpose intended thereby.
6.Registered Dealers & Independent Technicians: We may share information with our registered dealers and independent service technicians, who may use the information to facilitate purchases or provide repair or other services to you.
7.Aggregated Data: We may share certain information, including information obtained through analytics and tracking tools such as anonymous usage data, referring/exit pages and URLs, platform types, and number of clicks with our Service Providers. We aggregate or otherwise remove data of all personally identifying characteristics and may share that aggregated, anonymized data with our Service Providers.
Additional Information for U.S. Residents
Some states require that organizations disclose whether the following categories of Personal Information are collected, disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration.” The table below indicates the categories of Personal Information we collect and transfer in a variety of contexts. As this chart shows, we sell certain Personal Information to third parties.
|Category of Information||Sources of Collection||Business Purposes for Collection||Third Parties with Whom this Information is Shared/Sold and/or Disclosed|
|Unique identifiers such as name, signature, address, telephone email, account name, online identifier, IP address||
|Financial information such as credit card number, debit card number, or any other financial information||
|Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||
|Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement||
|Audio, electronic, visual, thermal, olfactory, or similar information||
|Inferences drawn from any of the information listed above||
Your Choices and Rights Regarding the Information We Have Collected About You
We provide certain tools and settings within the Lippert Services to help you access, correct, delete, transfer, or your information associated with the Lippert Services. We welcome you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data has collected about you, or to request an update, transfer, or deletion of your information. These services may also be available through your account if you have one with us. Please note that if you choose to delete your information or opt out of the collection and use of your information, you understand that certain features, including but not limited to access to the Lippert Services, may no longer be available to you.
Deactivating your Account
If you have registered your Personal Information with us, you can deactivate your account at any time. Once deactivated, your account will be irrevocably suspended, ensuring that nobody can use that account identifier again to prevent impersonation.
Do Not Track Signals
We do not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms.
Opting-Out of Communications
We may contact you with product and service-related announcements from time to time. We may also contact you for marketing related information, product discounts, coupons, offers, incentives, website updates, survey requests, reminders, industry news, and general company news.
You may opt-out of receiving certain communications from us by following the unsubscribe process described in an email communication, or by contacting us using the contact information provided below. However, please note you may not be able to opt out of certain Lippert Services-related communications, such as account verification, changes or updates to features of the Lippert Services, or technical and security notices.
If you reside in the UK or EEA, we only send you commercial emails when we have obtained your explicit consent, except where we have obtained your e-mail address in the course of a sale or negotiation of a sale of a product or service and where the commercial emails are only marketing similar products or services.
Privacy Rights for Certain Jurisdictions
Depending on the jurisdiction in which you are located or reside, you may also have the following additional rights with regard to Personal Information:
Access: You may have the right to request access to your personal data that we hold about you. This right enables you to receive a copy of this personal data from us.
Rectification or Deletion: You may have the right to request rectification or erasure of your personal data. This right enables you to ask us to delete or remove personal data where there is no legitimate reason for us continuing to process it. You also have the right to have incomplete Personal Information completed. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below). Please note that where we hold and process your personal data in order to comply with legal obligations, such as compliance with tax requirements and exemptions, or for the establishment exercise or defense of legal claims, your right to ask us to delete or remove your personal data is limited. We are not under an obligation to rectify or delete your personal data where to do so would prevent us from meeting our contractual obligations to you, or where we are required or permitted to process your personal data for legal purposes or otherwise in accordance with our legal obligations.
Object to Processing: You may have the right to object to our processing your personal data including for direct marketing purposes, or where we are relying on a legitimate interest (or those of a third party) in order to justify the basis for our processing your personal data and there is something about your particular situation which makes you wish to object to processing on this ground.
Opt Out of the Sale of Your Information: You may have the right to request that we not sell Personal Information that we have collected. If you exercise that right, please note that we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions. If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.
Restrict Processing: You may have the right to request that we restrict processing of your personal data. This right enables you to ask us to suspend the processing of your personal data under certain circumstances, e.g., if you want us to establish its accuracy or the reason for processing it.
Portability/Transfer: You may have the right to request the transfer of your personal data to another data controller where you provided that information to us.
If you want to exercise your rights, please contact us at the contact details below, setting out in writing your request clearly, including by specifying the personal data to which the request relates. You may also submit a request using our request form. We recommend that you provide as much detail as possible when sending your requests to us, and that you identify yourself clearly, so that we can deal with your query properly and efficiently. We do not discriminate against individuals that exercise state-conferred rights. If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal.” Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. We will only send verification questions from firstname.lastname@example.org. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our verification email address listed above, do not respond. Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:
- A letter or form signed by the individual indicating that you have authorization to act on the individual’s behalf.
- If you are submitting the request on behalf of an individual located in California and are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
We may store the information we collect about you for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. Following termination or deactivation of an Lippert Services Account, we may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes. After requests to delete or remove your information are received removed information may persist in backup copies maintained for system restoration purposes, typically for a period of seven (7) years or such other period prescribed by local law. Backup and restoration copies will be deleted earlier if technologically feasible and allowed or required by retention policies or local law.
Transfer and Storage Of Your Information
Please note information we collect about you may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers operate. Please be aware your Personal information may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that Lippert may transfer your Personal Information to the United States and process and store it there.
Please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. Such countries or jurisdictions may include, without limitation, the United States and other countries in which we or our subsidiaries, affiliates or Service Providers maintain facilities. In order to provide adequate protection for the transfer of your Personal Information, we have in place contractual arrangements (as appropriate) with our subsidiaries, affiliates and Service Providers in respect of such transfers. Specifically, hawse have adopted the Standard Contractual Clauses published by the European Commission on 4 June, 2021. If you are located in the UK or the EEA, you may request a copy of the Standard Contractual Clauses we use for the transfer of your data outside of the UK or EEA, which includes the categories of information transferred by contacting us using the contact information below. We will take all reasonable technical and organizational measures to safeguard Personal Information we transfer in such situations.
We take reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. We implement security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, we cannot guarantee the security of our systems or databases, nor can we guarantee that Personal Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from the Lippert Services is provided at your own risk. In the event that we are required by law to inform you of a breach to your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Please do your part to help us keep your information secure. You are responsible for maintaining control over operation of your Lippert Services, the confidentiality of your password and Lippert Services account(s), and are fully responsible for all activities that occur under your Lippert Services password or Lippert Services account(s). Please note that we may terminate your access to the Lippert Services and any license you have with Lippert related to the Lippert Services in the event it learns or suspects you have disclosed your Lippert Services account(s) or password information to an unauthorized third party.
The Lippert Services may link to other sites created and maintained by other public and/or private-sector organizations. Lippert provides these links solely for your information and convenience. When you transfer to an outside website, you are leaving the Lippert Services, and our information management policies no longer apply. We encourage you to read the privacy statement of the websites you visit before you provide any Personal Information.
Personal Information of Minors
Our web pages are not intended for children or minors under the age of eighteen years. Accordingly, we do not store or sell information from minors under the age of eighteen years. If you believe that a child has submitted personal information to us, please contact us at email@example.com and we will delete the information.
Additional Information for California Residents
The following information applies to California Residents:
Information Disclosed for a Marketing Purpose
Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), our customers who are residents of California may request certain information about our disclosure of Personal Information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at firstname.lastname@example.org with “Request for California Privacy Information – Shine the Light” on the subject line and in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
California Sensitive Information Disclosure.
We collect the following categories of sensitive personal information as defined under California law:
|Categories of Sensitive Personal Information We Collect||Purposes for which it is collected||Is information sold or shared for the purpose of cross-context behavioral advertising|
|Account log-in, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.||
|Racial or ethnic origin, religious or philosophical beliefs, or union membership.||
If you are visually impaired, you may access this notice through your browser’s audio reader.
All requests, questions, or concerns related to this Privacy Notice and how we process your Personal Information should be directed to Lippert by emailing email@example.com or calling us at 1-888-996-2813. If you would like to access, amend, erase, export (i.e., data portability), opt out of the sale of or object to or restrict the processing of Personal Data collected via our Site, you may submit a request via this form.
You may also contact one of our Data Protection Officers using the following contact information:
LCI ITALY S.R.L.: Agostino Oliveri, Sicurdata s.r.l., Via E. Codignola 10/a - 50018 Scandicci (FI), +39 055 750808, firstname.lastname@example.org;
SCHAUDT GMBH: Frederic Kellner, TDSSG GmbH, Am Hagelsrech 14 - 66806 Ensdorf, +49 6831-7641214, email@example.com
Depending on the region in which you are located, you may have the right to make a complaint at any time regarding our use of your Personal Information or the contents of this privacy statement to the national data protection authority in the country where you are based (e.g., the supervisory authority of your usual place of residence or work or place of the alleged infringement). You can find further details of all EU supervisory authorities here: https://edpb.europa.eu/about-edpb/board/members_en. If you are located in the UK, The supervisory authority in the UK is the Information Commissioner’s Office (ICO): firstname.lastname@example.org or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us at email@example.com.