1. Introduction
The purpose of this privacy policy is to provide information about how we, Thule Inc, process your personal data in connection with the use of our website (https://www.thule.com) and the services we provide through this website. We respect your privacy and protect the personal data we process about you.
We protect children’s integrity. Therefore, we do not intentionally process personal data relating to children under the age of 18.
The following describes, among other things, how we collect, process and share your personal data.
2. Purpose and legal basis for the processing of your personal data
U.S. privacy laws (including the California Consumer Privacy Act (CCPA/CPRA) and similar state laws) require businesses to describe the categories of personal information collected, the purposes for which it is used, and the rights available to consumers.
- When visiting our website
- (i) What personal data is being processed and why?
- Personal data collected through cookies entail e.g. your Internet Protocol (IP) address, browser language, geographical location data, demographic information, date and time, information about webpages, weblinks, and any other information on our website accessed by you.
- For processing of personal data collected through strictly necessary cookies, the purpose of such processing is to provide a functioning website.
- For processing of personal data collected through performance cookies, the purpose of such processing is to develop our website and improve its functions.
- For processing of personal data collected through functional cookies, the purpose of such processing is to improve usability and enable personal settings.
- For processing of personal data collected through marketing cookies, the purpose of such processing is to provide you with relevant offers via other channels. The information may be used for customer segmentation for advertising and online advertisements to advertise relevant products to you.
- (ii) What is the legal basis for the processing?
- When you send us a request
- (i) What personal data is being processed and why?
- (ii) What is the legal basis for the processing?
- When you buy a product online
- (i) What personal data is being processed and why?
- (ii) What is the legal basis for the processing?
- Fulfilling your purchase and delivering products.
- Providing customer service and order support.
- Maintaining records to comply with U.S. tax, accounting, and consumer protection laws
- When registering or logging in to a user account
- When making a return
- (i) What personal data is being processed and why?
- (ii) What is the legal basis for the processing?
- Processing returns and refunds to meet U.S. consumer protection obligations..
- Recordkeeping for accounting and fraud prevention.
- When making a compensation claim
- When making a product registration
- When we need to send product safety notices or conduct product recalls
- When we send out-of-stock emails
- When we send you marketing materials, and similar information
- Verifying your identity for legal compliance and sanctions checks
- Direct Marketing
- Any other method which becomes relevant from time to time.
- Service providers (hosting, analytics, fraud prevention, logistics)
- Payment processors
- Advertising and marketing providers (with consent where required)
- Completing transactions
- Providing customer support
- Warranty and product safety obligations
- Legal or regulatory compliance
- Right to know/access personal information collected
- Right to delete personal information
- Right to correct inaccuracies
- Right to opt-out of:
- Sale of personal information
- Sharing for cross-context behavioral advertising
- Targeted advertising
- Right to data portability
- Right to appeal a decision
When you visit our website, we can collect and/or store information about your visit by placing cookies. Cookies are small text files that a website or its service provider transfer to your computer's hard drive through your web browser. They enable us to recognize your browser and capture and remember certain information.
We collect and use website and cookie information for operational purposes based on our legitimate business interests.
We collect and share certain cookie data for targeted advertising only with your consent, where required by applicable U.S. state laws.
For more information about how we use cookies and similar technologies on our website please visit our Cookie Policy.
When you send us a request regarding e.g. your orders or purchased products, either via our contact form available through our support function or directly to one of our employees listed as contact persons on the website, we process the following personal data to be able to answer and fulfil your request: your e-mail address, name and telephone number if you choose to provide it, the country you come from, which category/contact reason the question concerns, a description of the topic and your question. We may use the information to contact you regarding your request by e-mail or telephone and to administer and handle your request.
We use this information to provide customer service and respond to your inquiry as part of our legitimate business operations under U.S. law.
If you want more information regarding how we made this assessment please contact us at privacy@thule.com.
In order to administer your order, to be able to deliver the products you have purchased online and to be able to follow-up on your order and any potential issues or requests arising in connection thereto, we process your name, billing address, delivery address, e-mail address, telephone number, payment method and information about the products you have ordered. Personal data relating to your payment (including personal identity number, bank details and account information or information about other payment methods) is processed by our collaboration partner, who act as a separate controller for its processing of personal data. Please see the privacy policy of the collaboration partners that is available upon collection of your personal data for information about its processing of your personal data.
Personal information processed includes email, password, name, address, and phone (optional). Used to provide your account, order history, faster checkout, and related services.
This processing is necessary to provide the account and support the transaction at your request
If you want more information regarding our legitimate interest assessment please contact us at privacy@thule.com.
Name, address, email, order details, payment information (as needed), signature if applicable.
If you want more information regarding our legitimate interest assessment please contact us at privacy@thule.com.
Processed information includes contact details, order information, bank name/account number (if reimbursement is issued).
We process this information to comply with warranty laws, product guarantees, and consumer protection requirements applicable in the U.S.
If you want more information regarding our legitimate interest assessment please contact us at privacy@thule.com.
Name, email, country, product details, and purchase date are processed to provide Extended Warranty or other product support.
This processing is necessary to administer product warranties and support services
If you want more information regarding our legitimate interest assessment please contact us at privacy@thule.com.
We process your name, address, email, purchased products, and phone number to send legally required safety notices and conduct product recalls.
We do this to comply with U.S. product safety and consumer protection laws, including requirements of agencies such as the U.S. Consumer Product Safety Commission (CPSC).
If you want more information regarding our legitimate interest assessment please contact us at privacy@thule.com.
We process email address, product information, and request timestamps based on your request.
This is done with your consent.
We use your name, email, country, product interests, and consent timestamps to send newsletters and marketing communications.
Marketing emails are sent only with your consent or as permitted by applicable U.S. law. You may unsubscribe anytime.
If you want more information regarding our legitimate interest assessment please contact us at privacy@thule.com.
In certain cases, we may verify your identity or check information to comply with U.S. sanctions, anti-fraud rules, and other legal obligations.
Information processed may include date of birth and other identifiers.
We may use information about you to provide you with information about products or services, promotions, special offers and other information which relates to our products or services or which we believe may be of interest to you. Where your consent is required, we will always ask you for it.
We may send you marketing information by:
3. Who has access to your personal data?
3.1 Sharing within the Thule Group
Only employees who need access to your information for business purposes will receive it.
Thule Inc. may share personal information with other Thule entities when needed to support U.S.-based consumers, including technical support and warranty services.
Please find information about the group companies that we share your personal data with here.
3.2 Sharing to third parties outside the Thule Group
We share information with:
Some of these parties may be considered “service providers” or “contractors” under U.S. privacy laws, and we impose contractual obligations restricting their use of your personal information.
If you would like to obtain more detailed information on who your data is shared with, please contact us at the contact information provided in section 5.
3.3 Sharing outside of the US
If your information is transferred outside the U.S., we take steps to ensure appropriate safeguards depending on local law.
International transfers occur only where necessary for service delivery and subject to contractual protections.
4. For how long do we store your personal data?
Retention periods are aligned to U.S. recordkeeping, tax, warranty, and consumer protection laws.
We retain information only as long as reasonably necessary for:
| Type of processing | Time period or criterion for determining the storage period |
|---|---|
| For logged in users with Thule account: Personal data collected in connection with registration, use of user account and placing orders or returns as logged in |
Your data will be stored and processed until you decide to delete your user account, unless the personal data must be stored longer in accordance with applicable laws, including applicable accounting legislation. |
| Guest checkout: Personal data collected in connection with placing orders or returns as a guest |
Stored for a maximum period of three (3) years. Certain personal data relating to your purchase will be stored for as long as required according to applicable accounting legislation. |
| Personal data collected in connection with a consumer service request |
Deleted continuously taking into account the type of request in question. However, stored for a maximum period of three (3) years. |
| Personal data collected through cookies in connection with usage of the website. | For more information on how long we store cookies on our website please visit our Cookie Policy. |
| Personal data being processed in connection with a compensation claim | Stored for a maximum period of three (3) years unless the personal data must be stored longer in accordance with applicable laws, including applicable book keeping legislation. |
| Personal data being processed in connection with a product registration | During the period of the Thule Extended Warranty applicable to the product you have registered. |
| Personal data being processed in connection with product safety notices and product recalls | Ten (10) years after we sent out the product safety notice or did the product recall. |
| Personal data used for sending out newsletters and similar marketing communications and advertisement | Your data will be stored and processed until you decide to unsubscribe. If you, before signing up, have visited thule.com and accepted the use of marketing cookies, then data from previous visits can be connected to your account and you might receive communication and advertisement based on these previous visits |
| Personal data used for sending out-of-stock emails | Stored for a maximum period of three (3) months. |
| Personal data collected in connection with an initiated not completed purchase (abandoned cart) | Stored for a period of two (2) weeks. |
| Personal data processed for the fulfilment of legal obligations under relevant accounting legislation. | Stored for a period of ten (10) years, unless a shorter period is required under local laws. |
5. Your U.S. Privacy Rights
U.S. state privacy laws (such as the CCPA/CPRA, Virginia CDPA, Colorado CPA, Connecticut Data Privacy Act, and others) grant certain rights to consumers.
These may include:
How to Exercise Your Rights Email privacy@thule.com or call (800) 238-2388
We will verify your identity before fulfilling your request, as required by U.S. laws. You may authorize an agent to submit a request on your behalf.
We will not discriminate against you for exercising your rights.
6. External Links
Our website may contain links to third-party websites. Their privacy practices are not covered by this notice.
7. Changes to This Privacy Notice
We will update this notice when necessary. Material changes will be communicated via prominent notice or direct communication (e.g., email).