SMS Privacy Notice

This SMS Privacy Notice supplements our larger Privacy Statement. This supplemental policy (the “SMS Privacy Notice”) describes how Innovative Water Care Solutions LLC, belonging to and part of Solenis LLC, and its subsidiaries (collectively “we,” “us,” or “our”) collects, uses, stores and discloses your personal information in connection with the HTH Textstrip Responder, a product offered by us (hereinafter “Textstrip Responder”). By using the Textstrip Responder, you represent that you have read and agree to this supplemental Privacy Notice and the other disclosures made as part of Solenis’ Privacy Statement, in addition to the Textstrip Responder Terms and Conditions. If you do not agree with this SMS Privacy Notice, do not access or use the Textstrip Responder.

This supplemental privacy notice provides additional information for purposes of compliance with applicable data privacy laws.

Personal Data Collected and Shared: Please note that we do not sell the data obtained through Textstrip Responder. We do however collect and may share with our service providers and third party processors the below information as it pertains to our customers who use Textstrip Responder:

• Personal identifiers such as phone numbers, name, address, email address, etc. (“Personal Identifier”)
• Information concerning when the customer opted into receive text messages or otherwise visited our website (“Opt-In and Web Access Information”)

Category of Personal Information Collected: We collect the above noted Personal Data from the following sources:

• Textstrip Responder customers

Business/Commercial Purpose of Collection: We collect the above noted Personal Data for the following business/commercial purposes:

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to obtain information on what chemicals are needed to treat your pool, we will use that information (i.e., the image sent to us) to process your request.
• We may also save your information to facilitate pool assistance in the future.
• Customers who opt into receive marketing communications may also receive, without limitation, product announcements, pool care tips, product recommendations, educational information, promotions, and other marketing campaign communications via text message.

In addition to, and consistent with, the uses and sharing described in this SMS Privacy Policy, we may use and disclose the below categories of Personal Data as set forth below:

Category of Third Party to Which Personal Data is Disclosed: We share all of the above Personal Data with the following third parties for the following purposes:

• We share Personal Identifiers and Opt-In and Web-Access Information with our information technology service providers, including Salesforce, which helps us keep track of your communications with us across platforms, including text messages, emails, and mobile applications and otherwise provide the Textstrip Responder to you.
• We share Personal Identifiers, Pool Information, and Opt-In and Web-Access Information with Twilio, the text message platform for the Textstrip Responder. Twilio retains all of this data until and unless deletion is requested.

Retention: We may retain data collected pursuant to this SMS Privacy Policy for as long as is needed to serve or fulfill the purposes outlined in this SMS Privacy Policy or until a given consumer asks us to delete his or her data, pursuant to the procedures below. Further, Personal Data is retained in accordance with our policies and practices, applicable law, and contractual obligations. We may be required to retain Personal Data for a longer period of time where required to do so under applicable law or government order.

Your Rights: Please note that you may have specific rights when providing your Personal Data to us when using Textstrip Responder under applicable laws in your jurisdiction—subject to all applicable limitations, exemptions, or exceptions. Please note that when referring to “Personal Data” it is limited to your Personal Data in relation to Textstrip Responder. Please see our privacy policy here www.solenis.com/en/privacy-statement as it relates to your Personal Data on our website, or when using other services. These rights may include, solely to the extent applicable and to the extent granted under applicable law:

• Right to Know and Access: You have the right to know whether or not we use your Personal Data, as well as the following information: a) what Personal Data we have collected about you; b) the categories of sources from which Personal Data about you was collected from; c) for what business purposes we collect your Personal Data; d) if we share your Personal Data to and with third parties; e) for what business purposes we share or sale your Personal Data for; f) what categories of third parties we share your Personal Data with; g) the specific pieces of Personal Data we have collected about you (e.g., data portability); and h) how long we retain your Personal Data. Please either call us (866)-HTH-POOL or email us at privacy@solenis.com or feedback@solenis.com. You can also use Data Request Form or Contact Us section available on our website.
• Right to Deletion: You have the right to request that we delete your Personal Data and that we notify any service providers, contractors, and/or third parties to delete your Personal Data from its records. However, your Personal Data may not be deleted under certain circumstances allowed by law. When you submit a request to delete your Personal Data, and we are unable to do so because a specific exemption applies, we will inform you at that time the reason we are unable to comply with your request. Please either call us (866)-HTH-POOL or email us at privacy@solenis.com or feedback@solenis.com. You can also use Data Request Form or Contact Us section available on our website.
• Right of Correction: You have the right to request that we correct any inaccurate Personal Data. You can do this by emailing us at privacy@solenis.com or feedback@solenis.com. You can also use our Data Request Form or Contact Us forms or call us at (866) HTH POOL.

You may also opt out of receiving future text messages from Textstrip Responder by texting “STOP” at any time.

We do not sell your Personal Data to third parties, nor do we share your Personal Data for purposes of cross-contextual behavioral advertising as may be defined under applicable law. Additionally, we do not use your Personal Data to profile you in furtherance of decisions that produce legal or significantly similar effects (as may be defined under applicable law).

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We will respond to your request within the applicable timeframe required under applicable law. If we deny your request, you can appeal such denial by emailing us at privacy@solenis.com.

Authorized Agent: You may use an authorized agent to submit Personal Data requests, including through the use of a technology including, but not limited to, an Internet link or a browser setting, browser extension or global device setting, indicating your intent to opt out of certain processing of Personal Data. To use an authorized agent, you must provide the agent with a signed authorization. We may require the agent to provide us with proof of the signed authorization. In addition, we may require you to verify your identity with us and directly confirm that you authorized the agent to submit the Personal Information request on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to applicable state or provincial law.

Non-Discrimination: We will not discriminate against you for exercising any privacy rights. However, we may charge a person a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the person’s voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program and the difference is reasonably related to the value provided to us by that person’s Personal Data. In addition, we may offer financial incentives, including payments as compensation, for the collection of Personal Data, the sale of personal information, or the retention of personal information. We may also offer a different price, rate, level, or quality of goods or services to a person if that price or difference is directly related to the value provided to us by your Personal Data. We will only enter you into a financial incentive program with prior opt-in consent which clearly describes the material terms of the financial incentive program, and which may be revoked by you at any time. We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

Protecting Children’s Privacy: Textstrip Responder is not intended for the use of children under the age of 16, nor do we have a reason to believe children use this program. Textstrip Responder does not knowingly collect Personally Identifiable Information from any children under 16 years of age. If you learn that a child has provided us with Personal Data, then you may contact us at feedback@solenis.com.

Data Minimization: We practice data minimization and collect data that is only reasonably necessary and proportionate to achieve a limited specific purpose(s) for which the Personal Data is collected and or processed.

Protecting your Data: We establish, implement, and maintain reasonable administrative, technical, physical, electronic, and procedural safeguards based on industry standards for like-sized businesses based on the volume and type of data we collect and handle. We work to reduce reasonably foreseeable risks in connection with the collection, storage, and disclosure of your Personal Data.

Contacting Us: If you have any questions about our supplemental privacy policy or practices or if you feel that we have not handled information about you properly, please contact us (866)-HTH-POOL or email us at privacy@solenis.com or feedback@solenis.com.

Updates: Our SMS Privacy Policy as it relates to our SMS program may change occasionally and we reserve the right to update this SMS Privacy Policy at any time with all updates effective upon posting. We will endeavor to inform our contacts of major changes to the policy. You may always review our SMS privacy supplement or our overall larger Privacy Statement.

Last Modified: April 7, 2023