SoClean Privacy Policy

Introduction & Scope

SoClean, Inc., and its subsidiaries and affiliates ("SoClean," "we," or "us") are committed to protecting your privacy and handling your Personal Information in a respectful, transparent, fair, and lawful manner. This Privacy Policy ("Policy") explains how we may collect, use, disclose, and safeguard your Personal Information across SoClean.com, related mobile apps, and digital services (collectively, the “Services”). It also outlines additional rights and obligations under U.S. state privacy laws (e.g., CCPA/CPRA, VCDPA, CPA, CTDPA, UCPA, TDPSA, etc.).

Personal Information means information that can reasonably be used, directly or indirectly, to identify you. It does not include data that is anonymous, de-identified, or aggregated under applicable law. This Policy is incorporated into and made part of our Terms of Service ("Terms"). If you do not understand our Policy, please contact us using the information in the "Contact Us" section below. By accessing or using our Services, you expressly consent to our collection, use, and disclosure of your Personal Information in accordance with this Policy.

Information We Collect About You and How We Collect It

We may collect the following categories of Personal Information:

• Identifiers: Name, device identifiers, postal address, email address, phone number, IP address;
• Commercial / Transactional: Purchase history, payment information, billing/shipping address, customer service history (including any correspondence);
• Sensitive Personal Information: Health information (relating to product usage or warranty), biometric data (if collected);
• Internet or Electronic Network Activity: Browsing history, interactions with the Services, ads, cookies / analytics data;
• Geolocation Data: Broad location (e.g. city) or precise location if enabled and permitted; and
• Inferences / Profile Data: Preferences, interests, behavior predictions

We may collect the categories of Personal Information listed above in the following manner:

• Directly from you when you provide it to us. For example, when you create an account, take a survey, contact customer service, opt-in to marketing communications or place an order, certain identifiers must be collected.
• When you share the information with others. We may collect Personal Information when you share content or communicate with others through our Services. What you choose to disclose is up to you. Information you provide may be visible to our business partners and service providers who help operate our Services. Because others may also view what you share, only provide information you’re comfortable disclosing.
• From third parties. We may collect your information from marketing partners, public data sources or service providers.
• Automatically as you navigate through the Services. This may include usage details, IP addresses, and data gathered through cookies, tracking pixels, or similar technologies. We may combine this data with other Personal Information we hold. For more details, please see the section titled, Cookies, Tracking & Similar Technologies, below.

Cookies, Tracking & Similar Technologies

As you interact with our Services, we and our service providers use various technologies to automatically collect certain information about your device, browsing activity, and usage patterns. This may include your IP address, device identifiers, operating system, browser type, and details about how you navigate or interact with our content.

These technologies help us deliver functionality, personalization, analytics, security, and advertising features. The technologies we use may include:

Cookies: Small text files placed on your device to recognize you, remember your preferences, and enable core site functionality. You may manage cookie settings through your browser or device settings. Note that disabling cookies may impair certain features.

Pixels and Tags: Small code snippets or transparent images that help us measure engagement (for example, tracking whether an email was opened or a page was viewed) and support analytics and advertising functions.

Third-Party Technologies: Some content or advertising on our Services is provided by third parties, including ad networks and content providers. These third parties may use their own cookies or similar tracking technologies to collect information about your activity across websites and apps to provide interest-based advertising. We do not control these technologies. For information about opting out of targeted advertising, please see Your Rights (Where Applicable) below.

Analytics Tools: We use analytics providers, such as Google Analytics, to better understand how users interact with our Services. These tools use cookies and similar technologies to collect and report information to us. For details on Google Analytics, visit https://support.google.com/analytics.

Tracking Signals

We may combine information collected automatically with other Personal Information we maintain. Our Services currently recognize Global Privacy Control (GPC) signals where required by law. We do not respond to older “Do Not Track” (DNT) browser signals.

How We Use Personal Information

We may use your information for the following business purposes consistent with applicable state laws:

• To detect, prevent, and respond to fraud, misuse, and security incidents;
• To process orders, payments, returns, and customer support;
• To personalize content, recommendations, and ads;
• To send transactional communications (e.g. order confirmations, shipping notices);
• To provide, maintain, and improve our products and Services;
• To comply with legal obligations, enforce our rights, or defend litigation, including for billing, financing, and collection;
• To notify you about changes to our Services or any products or services we offer or provide through it;
• To send marketing and promotional offers such as Direct Mail, Email, and Mobile SMS (Text) (where permitted or opted in);
• To allow you to participate in interactive features on our Services;
• To aggregate, de-identify, or anonymize data for analytics, research or other business insights that may be provided by third parties; and
• For any other purpose with your consent.

Under applicable privacy laws, we will limit use of Personal Information to the purpose for which it was collected or recognized as compatible, unless you consent to additional use or the law otherwise permits.

Sharing, Selling, or Disclosure of Your Personal Information

We do not “sell” your Personal Information for money in the traditional sense, but in some jurisdictions “share” or “sell” may have broader meanings (e.g. for cross-context targeted advertising). If we ever engage in practices that qualify as a sale or share under applicable law, we will provide required notices and opt-out mechanisms.

We may disclose your Personal Information to Recipients as follows:

• To our subsidiaries and affiliates;
• To our Business Partners, to provide you with the products you request through the Services;
• To Service Providers that may perform marketing services, process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information on our behalf to provide services available on the Services;
• To a party to a corporate transaction, including buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our or its assets;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others, including the use of your information to detect, investigate, and prevent fraudulent transactions, illegal activities, and violations of our Terms;
• For any other purpose disclosed by us at the time of collection or when you provide your consent;
• To Advertising and Analytics Providers. We may share information, including your device and network information, preferences, demographics, and geolocation information; and
• To Durable Medical Equipment ("DME") Distributors. We may share information, including your personal identifiers and contact information, with DMEs for marketing purposes.

We will require to limit their use and protect your data consistent with this Policy and applicable law.

Your Rights (Where Applicable) We strive to provide you with choices regarding your Personal Information. We have mechanisms in place that allow you to control your preferences. Additionally, depending on your state of residence, you may have additional rights under applicable consumer privacy laws:

• Right to Access / Know — Request to know what Personal Information we collected about you, sources, purposes, disclosures, and recipients. Follow this link to Request Information.
• Right to Correct / Rectify — Request correction of inaccurate or incomplete Personal Information. Email info@soclean.com to request a correction. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
• Right to Delete / Erase — Request deletion of your Personal Information (subject to certain exceptions; see Data Retention and De-Identification below). Follow this link to Delete Information.
• Right to Data Portability — Receive your Personal Information in a portable, machine-readable format (subject to certain exceptions). Follow this link to Request Information.
• Right to Opt Out of Sale / Sharing / Targeted Advertising — Opt out of sale, sharing, or the use of your data for certain advertising. Follow this link to Do Not Sell Request. You may opt out of collection of your personal information cookies, tracking pixels, or similar technologies on SoClean.com through opt out options available when you first visit SoClean.com.
• Right to Limit Use of Sensitive Personal Information — Limit processing of your sensitive data to certain purposes. Email privacy@soclean.com
• Right to Non-Discrimination — We will not discriminate against you for exercising your rights (e.g., by denying service, charging different prices, etc.).
• Ability to Unsubscribe from Marketing: We offer you the ability to opt out of receiving Email or SMS (Text) communications within the communication itself. Alternatively, you can contact us to opt out using the contact information found in the "Contact Us" section at the end of this Policy.
• Opt Out of Third-Party Advertising: Unless you opt-out using GPC or another opt-out indicator, we may disclose your IP address to a third-party advertiser. We do not control their collection or use of your information to serve interest-based advertising. However, some third parties may provide you with ways to opt out of receiving targeted ads from within the advertisement you received.
• Ability to Opt Out of Abandoned Cart Messages: SoClean uses cookies to collect information around abandoned shopping carts. A cart is considered abandoned within one hour of inactivity / lack of purchase. Once the cart is considered abandoned, an Email and/or SMS (Text) message will be sent as a reminder to customers who have approved receipt of SMS (Text) messages from us. You may opt out of these messages from within the communication. Alternatively, you can contact us to opt out using the contact information found in the "Contact Us" section at the end of this Policy.

Data Retention & De-Identification

We will retain your Personal Information only for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, enforce agreements, or as otherwise permitted by law. In some jurisdictions, we may retain a subset of information for record-keeping, statutory, or audit purposes.

Where feasible, we may de-identify, anonymize, or aggregate data so that it can no longer be associated with you. Once data is de-identified, it is not subject to this Policy.

Security

We employ reasonable administrative, technical, and physical safeguards designed to protect your Personal Information from loss, unauthorized access, alteration, or misuse. However, no security measure is perfect or impenetrable.

We are not responsible for the information collection, use, disclosure, or security practices of other organizations, such as Meta, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to such other organizations through or in connection with the Services.

If a data breach occurs involving your Personal Information, we will provide notice consistent with applicable laws.

Minors

Our Services are not directed to children under 18 (or as legally defined in your jurisdiction). We do not knowingly collect Personal Information from minors without parental consent. If we become aware of a minor’s Personal Information in violation of this Policy, we will take steps to delete it as required by applicable law.

Additional Disclosures for California Residents

If you are a California resident, the following additional disclosures apply:

• Do Not Sell or Share My Personal Information — You may opt out of sale or sharing of your Personal Information (as defined under CCPA/CPRA).
• Shine the Light — Under California’s “Shine the Light” law, California residents may request certain disclosures about third parties with which we have shared Personal Information for marketing.
• CPRA / California privacy authority — This Policy is intended to satisfy CPRA obligations as enforced by the California Privacy Protection Agency.
• Limit Use of Sensitive Personal Information — California law requires that we limit the use of sensitive categories of data unless we obtain opt-in consent or meet narrow exceptions.

Additional Disclosures for Other States

To the extent required by state law, this Policy is intended to comply with the following state laws’ requirements regarding the consumer rights, notice, and processing limitations:

• Virginia, Colorado, Connecticut, Utah, Iowa, New Hampshire, New Jersey, Maryland, Minnesota, Tennessee, Kentucky, Rhode Island, Indiana, Nebraska, Oregon, Texas, Montana, and Delaware
• In particular, we adopt the following practices:
1. Data Minimization & Purpose Limitation — We collect only what is necessary, and for only the purposes disclosed.
2. Vendor Contracts & Use Restrictions — We require Service Providers to abide by contractual limitations consistent with state law obligations.
3. Consumer Verification — In states requiring verification, we will verify requests through a reasonable method prior to fulfilling.
4. Timing / Response Periods — We will respond to privacy requests (e.g. access, deletion) within legally mandated timeframes (usually 30–45 days) or notify you if an extension is needed.
5. No Retaliation / Discrimination — We will not treat you differently (e.g. deny you service, charge different prices) for exercising your privacy rights.

Third Party Links and Services

Our Services may contain links to or integrations with websites and services operated by third parties not affiliated with SoClean. We are not responsible for the content, privacy practices, or policies of those third parties. When visiting another site or using a third-party feature, you should review its privacy policy, as it may differ from ours. This Policy applies only to information collected through our own Services.

Note to International Users

Our Services are intended for individuals located in the United States. If you visit our Services or contact us from outside of the United States, please be advised that (1) any information you provide to us or that we automatically collect will be received in the United States and may be transferred to other jurisdictions; (2) that by using our Services or submitting information, you explicitly authorize its processing in the United States and subsequent transfers outside the United States in accordance with this Policy; and that U.S. law may not offer the same privacy protections as the law of your jurisdiction.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time (e.g, to comply with new laws or reflect changes in our practices). We will post the updated version with a new “Last Updated” date and provide notice where required by law (e.g. via email or conspicuous website notice).

You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Policy to check for any changes. Your continued use of the Services after the effective date of the revised Policy will constitute your acceptance of the changes.

Contact Us

If you have any questions, concerns, or wish to exercise your privacy rights, you may contact us:

SoClean, Inc.
Attn: Privacy
1 Vose Farm Road
Peterborough, NH 03458
Email: privacy@soclean.com
Phone: 800.929.0338

Severability & Other Terms

If any provision of this Privacy Policy is invalid or unenforceable under applicable law, that provision will be limited or eliminated to the minimum extent necessary and the remainder of the Policy will remain in full force and effect.