CORE IoT CLOUD PRIVACY NOTICE

Effective Date / Date of Last Revision:  December 12, 2023

1. WHO WE ARE
2. HOW TO CONTACT US
3. WHY WE COLLECT DATA AND HOW WE COLLECT IT
4. PROTECTING YOUR PRIVACY GENERALLY
5. CHILDREN'S PRIVACY
6. TYPES OF INFORMATION WE COLLECT
7. HOW WE SHARE PERSONAL DATA
8. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA GENERALLY
9. SECURITY
10. LINKS TO THIRD-PARTY SITES
11. DATA RETENTION
12. ACCESSIBILITY
13. YOUR STATE PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES
14. NOTICE TO CALIFORNIA RESIDENTS
15. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA

1. WHO WE ARE

Briggs & Stratton, LLC (“Briggs,” “we” or “us”) develops and provides innovative products and diverse power solutions to help people get work done. Briggs & Stratton is the world’s largest producer of engines for outdoor power equipment, and is a leading designer, manufacturer and marketer of lithium-ion battery, standby generator, energy storage system, lawn and garden, turf care and job site products.  Briggs has developed its Core IoT Cloud application (“App”) which permits users to update and track Briggs’ swappable batteries (the “Services”).

Some of the data Briggs collects via the App and Services is considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”).  Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual.  It does not include deidentified or anonymized data.

The purpose of this Privacy Policy is to disclose to you how we collect, use and share Personal Data and how we attempt to safeguard the Personal Data we collect and process.  We are committed to securing the Personal Data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws.  We may update this Privacy Policy from time to time.  When we do, we will post an amended version of the Privacy Policy on the App.  Please review this Privacy Policy periodically.

2. HOW TO CONTACT US

If you have questions regarding this Privacy Policy, data protection or your rights, please contact us at:

Briggs & Stratton, LLC
12301 W. Wirth Street
Wauwatosa, WI 53222
1-800-444-7774
privacy@basco.com

3. WHY WE COLLECT DATA AND HOW WE COLLECT IT

We collect, process and use Personal Data to provide our App and Services. For example, we use the Personal Data we collect to: 

• Communicate with you;
• Provide you with information, quotes and offers;
• Provide our Services and permit you to access information regarding your Briggs & Stratton batteries;
• Process your account registration;
• Provide you with support;
• Personalize your experience on our App.
• Improve our Services;
• Measure the performance of our App and Services;
• Audit current interactions and transactions with consumers;
• Protect the security and integrity of the App and Services;
• Maintain, improve and customize our products, App and Services;
• Investigate, prevent or take action regarding illegal activities, suspected fraud or violations of our terms of use;
• Efficiently maintain our business;
• Comply with applicable law; and
• Defend our legal rights and the rights of others.

We obtain Personal Data directly from you and from your devices as described in this Policy and any other privacy notices we may provide to you when you interact with us.
 

4. PROTECTING YOUR PRIVACY GENERALLY

We utilize industry-standard security measures to safeguard the information we collect, maintain and use through the App and Services. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration or destruction. However, we do not and cannot guarantee the performance or adequacy of such security measures.

5. CHILDREN'S PRIVACY

Our App and Services are not intended for children under the age of sixteen (16) years old. As such, we do not intentionally collect, process or sell any Personal Data from consumers under the age of sixteen (16) years of age.

6. TYPES OF INFORMATION WE COLLECT

a. Information You Provide Directly To Us. We may collect the following categories of Personal Data if you provide it to us:

• Contact and company information and identifiers (such as name, company name, business type, business segment or specialty, job function, products produced at your company, title, address, telephone number(s) and electronic mail address);
• Information you provide to us when inquiring about our services;
• Information about your device (device id) if you agree to receive push notifications;
• Information about your battery location if you consent to connect via Bluetooth and provide permission for us to access your location;
• Your social media and browser account information when you sign onto our app via single sign on functionality; and
• Any other information you provide to us, such as any notes you provide about your battery and/or account.

b. Information We Receive from Third Parties. We may collect information regarding your identity if you elect to sign onto our App through a third party profile, such as Google or Facebook.

c. Information We Receive Via Bluetooth Technology. Our App permits you to connect your Briggs & Stratton batteries to the App via Bluetooth technology.  If you connect the App to your batteries, our App will receive information about your battery, including (without limitation) performance information, voltage, current, and location.
 

7. HOW WE SHARE PERSONAL DATA

We may share or provide access to Personal Data to others in the following ways:

• With Service Providers.  We may share information with service providers who:
  • perform data services on our behalf, such as data analytics, hosting and managed services; and
  • provide other services on our behalf, such as advertising services, accounting services, call center services, client relationship management services, and other various business services.
• With Other App Users Upon Your Request. You may elect to share data regarding your batteries if you choose to within the App.
• To Meet Our Legal Requirements or Exercise Our Rights.  We may share information with third parties in the following instances:
  • When we are required to do so by law.
  • In connection with any legal proceedings or prospective legal proceedings.
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
  • When we reasonably believe it is appropriate to apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal data.
  • We may share information with other persons or entities as part of our own corporate transactions, such as during financing or any asset sale.
     

8. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA GENERALLY

We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties. 

• You may decline to provide information.  You have the right to decide not to share information with us.
• You may delete your account and account information.  You have the right to delete your account and account data from within your account settings.
  
  PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE NOT TO PROVIDE US WITH CERTAIN INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH SOME OF OUR SERVICES.
  
  
• You may opt out of marketing communications and other features. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls and postal mail.  To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails.  Likewise, you can choose to opt out of sharing of your location data and data tracking across sites through the App.
   

9. SECURITY

When you register for an account with us, you may be required to choose a password which enables you to access our App.  You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone.  If your password is compromised, change  your password within your account.  If you believe your account may have been compromised, please notify us immediately.

We take industry standard security measures to protect your information. We also have put into place appropriate agreements and/or procedures with our service providers to ensure that your Personal Data is treated consistent with applicable data privacy and security laws. Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your Personal Data, we cannot and do not guarantee the security of your data.

10. LINKS TO THIRD-PARTY SITES

Our App may contain links to other websites and companies that may be of interest to you.  If you click on any of those links, you will leave our App.  We are not responsible for third-party websites.  Please consult the terms of service and privacy policies of those sites when you visit them.

11. DATA RETENTION

We will store your Personal Data for as long as: (a) you maintain an account with us; (b) you continue using our App and Services; (c) your Personal Data is stored in our back up servers and/or services; (d) in accordance with our retention policies and schedules; and (e) as long as we are legally required to retain the Personal Data.

12. ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities.  If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing on our App or Services, please email us at privacy@basco.com.

13. YOUR STATE PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “NOTICE TO CALIFORNIA RESIDENTS” section below. For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your personal data and to access such personal data;
• The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. When we engage in those activities, we sell personal data (i.e., information from cookies) to third-party advertisers and analytics companies. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request by emailing us at privacy@basco.com or by calling us at 1-888-914-9661, then enter PIN #599 157. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through emailing us at generalcounsel@basco.com.

14. NOTICE TO CALIFORNIA RESIDENTS

This Privacy Notice to California Consumers (“CA Notice”) is for California residents and supplements the other sections of this Privacy Policy.  This CA Notice explains how we collect, use and disclose your “Personal Information” (as that term is defined by California law) and how you may exercise your rights under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”).  This Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you.

A. NOTICE AT COLLECTION OF PERSONAL INFORMATION. To provide you with our App and Services, we collect and process information about you, including in some cases, Personal Information.  To comply with the CCPA and to assist you in understanding our data collection and protection practices during the past 12 months:

• Categories of Consumer Personal Information.  We collect and, in the 12 months prior to the Date of Last Revision of this Privacy Policy, have collected the following categories of consumer Personal Information:
  • Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name)
  • Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
  • Commercial information (records of personal property, products or services purchased, obtained or considered)
  • Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
  • Geolocation data
• Sources of Personal Information.  We collect the above categories of consumer Personal Information from you, from your devices, your browsers and third parties as described in Section 6 above.
• Purpose for Collection.  In addition to the business purposes for which we collect consumer Personal Data described in Section 3 above, we collect consumer Personal Information for the following business or commercial purposes:
  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
  • Providing advertising and marketing services for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
• Sale and Sharing of Personal Information.  Briggs does not “sell” Personal Information, as that term is commonly interpreted, nor does it use personal information in cross context behavioral advertising.  However, we do engage in targeted advertising activities that may constitute a sale or a share of Personal Information under California law. The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.  Please note that not all categories of personal information were necessarily shared with all categories of recipients listed.

  Category of Peronsal Information	Categories of Recipients
  Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email addressaccount name)	Business partners; lead purchasers; data hosting and cloud storage providers; mailing providers; advertising service providers; accounting service providers; call center service providers; client relationship management service providers; payment processing vendors.
  Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)	Data hosting and cloud storage providers; cookie management service provider; advertising service providers.
  Commercial information (records of personal property, products or services purchased, obtained, or considered)	Business partners; other App users; data hosting and cloud storage providers; mailing providers; advertising service providers; accounting service providers; call center service providers; client relationship management service providers; payment processing vendors.
  Geolocation data	Data storage providers; security, anti-fraud, and verification providers; data hosting and cloud storage providers.

• Sensitive Personal Information.  We do not use Sensitive Personal Information (as it is defined in the CCPA) for the purpose of inferring characteristics about individuals.
• Retention of Personal Information.  We retain Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
• Your Rights.  Under the CCPA, you have the following rights:

  RIGHT TO KNOW	You have the right to request that we disclose to you the Personal Information we collected about you in the 12-month period preceding your request.  This right includes the right to request: (1) specific pieces of Personal Information we have collected about you; (2) categories of Personal Information we have collected about you; (3) categories of sources from which the Personal Information was collected; (4) categories of Personal Information that we sold or disclosed for a business purpose about you (if applicable); (5) categories of third parties to whom your Personal Information was sold or disclosed for a business purpose (if applicable); and (6) the business or commercial purpose for collecting or, if applicable, selling your Personal Information.
  RIGHT TO DELETE	You have the right to request that we delete your Personal Information that we have collected from you, with some exceptions.  Note that if you request that we delete your information, we may be unable to provide you with certain offers or services.
  RIGHT TO CORRECT	You have the right to correct inaccurate Personal Information we maintain about you.
  RIGHT TO OPT OUT OF SALE	If we sell or share Personal Information, you have the right to opt out of the sale or sharing.  Briggs does not sell or share your Personal Information for cross context behavioral advertising.
  RIGHT TO LIMIT PROCESSING OF SENSITIVE PERSONAL INFORMATION	If we use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use and disclosure.  Briggs does not use or disclose Sensitive Personal Information for purposes other than for the limited purposes permitted by the CCPA and its regulations.
  RIGHT TO NON-DISCRIMINTATION	You have the right to non-discrimination for exercising your CCPA rights.  This means we cannot deny you goods or services, charge you different prices, or provide a different level of quality of goods or services just because you exercise your rights under the CCPA. Briggs will not and does not discriminate against you or other customers for exercising any of your CCPA rights.

• How to Exercise Your Rights
  
  Right to Submit a Request to Know, Delete and/or Correct:  You may submit a request to know, delete and/or correct by calling us at 1-888-914-9661, then enter PIN #599 157 or emailing us at privacy@basco.com.  If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
  
  Our Process for Verifying a Request to Know, Delete, and/or Correct.  We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
  
  We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.
  
  Right to Opt Out of Sale or Sharing of Personal Information.  We do not sell Personal Information or share Personal Information for cross context behavioral advertising.
  
  
• Shine the Light Law.  California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). If you would like to request information, please contact us at privacy@basco.com.
   

15. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA

The General Data Protection Regulation (“GDPR”) applies to individuals located in the European Economic Area (“EEA”).  The GDPR allows us to collect and use personal information from individuals within the EEA only for one or more of the following reasons: 

1. To fulfill a contract we have with you;
2. When we have a legal duty;
3. When it is in our legitimate interest; or
4. When you provide consent.

If you reside in the EEA, you have a number of rights under data protection laws in relation to the way we process your Personal Data, which are set forth below.  You may contact us directly to exercise any of these rights, and we will verify your request and, if appropriate, respond to any request received from you within one month from the date of the request. In exceptional circumstances we may need to extend this timescale, but we will always tell you in advance if we do, and our reasons why.

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, please get in touch with our team through the contact information provided in Section 2 of this Privacy Policy.  You may also reach out to your applicable Data Protection Authority (“DPA”) for more information.  There is a DPA located in each EU Member State.