Privacy Policy

Effective Date: January 31, 2022

Hydrofarm Holdings Group, Inc. our subsidiaries and affiliated brands located in North America (the “Company”) has adopted this Privacy Policy to inform you of our privacy practices, including how your personal information is collected, used and disclosed in the course of providing our products and services to you. Protecting your personal information is one of our highest priorities, and our commitment to privacy includes ensuring the accuracy, confidentiality and security of your personal information. If you are located outside of North America, the policies of our affiliates in those countries will apply.

SCOPE OF THIS POLICY

This privacy policy governs the collection of personal information from or about you, and how we use and disclose that information. It also governs how you may request access to and correction of personal information we have collected. We have operations both inside and outside the United States. This privacy policy applies to and governs the collection, use and disclosure of personal information in connection with our business activities in the United States and Canada, including from physical locations in the United States and Canada, and from our U.S. and Canadian websites. Our policy is to comply with the privacy laws of each jurisdiction in which we operate. Sometimes privacy laws and/or an individual’s right to privacy are different from one jurisdiction to another.

All references in this privacy policy to “Hydrofarm”, “Hydrofarm Group”, “Company”, “we”, “us”, “our” and similar terms are references to Hydrofarm Holdings Group, Inc. together with our subsidiaries and affiliated brands.

WHAT IS PERSONAL INFORMATION?

We collect and maintain different types of personal information about the people with whom we interact. We collect personal information that you provide to us or that we otherwise obtain through both online and offline interactions. For example: we collect personal information online when you request product information or purchase a product through one of our websites, create an account on one of our websites, apply for a job with a Hydrofarm Group company through one of our websites or subscribe to email newsletters and content, and we collect personal information when you call our customer service center, register warranty information by mail or otherwise interact with us without using any of our websites.

We may collect the personal information you provide when:

Purchasing, ordering, returning or exchanging any of our products and services online, over the phone or in person;
Requesting a copy of an invoice
Requesting a quote, special order or information about any of our products and services; Requesting a copy of an invoice
Contact our customer service staff; Contact our customer service staff
Apply for a job;
Make comments or suggestions to us; or Visit our websites or any of our physical locations.

The personal information we collect includes the following:

Contact and identifying information, such as name, address, telephone number and email address.
Information regarding the products and services we provide or receive from you, including with respect to the service, maintenance and repair history of such products;
Credit and financial information, such as payment methods and preferences, and billing and credit history;
Business relationship information, including information regarding your agreements, preferences, advisors and decision makers; and Customer relationship information, such as customer service requests and feedback and information requested or provided by you.

We may also collect market-related information, which may include personal information, relating to market trends and activities affecting our business. This information may include contractual terms, financial information and other information for market analysis and strategic planning purposes. We may also collect information related to our public, media and investor relations activities, as well as information related to our interactions with financial and other analysts and advisors.

If the personal information we collect about you is held by a third party, we will obtain your permission before seeking this information from such sources (such permission may be given directly by you or implied by your actions). Among the third parties from whom we may collect information are credit reporting agencies (for the purpose of performing a credit check when you wish to obtain credit from us).

From time to time, we may utilize the services of third parties (including other members of the Hydrofarm Group) in our business and we may also receive personal information collected by those third parties in the course of performing their services for us or otherwise. In this event, we will take reasonable steps to ensure that such third parties have represented to us that they are entitled to disclose your personal information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the personal information we collect in order to manage and develop our business and operations, including for the following purposes:

to establish, maintain and manage relationships with our customers (for example, we will use personal information to establish a customer’s identity and location so that we can accurately deliver and bill for products and services);
to establish, maintain and manage relationships with our suppliers; and
to analyze customer needs with respect to our products and services so that we can work to improve our products and services;
to communicate with suppliers in order to improve the products and services they provide to us; and
to enable us to inform you of products and services that members of the Hydrofarm Group, or third parties that we have carefully selected as partners, may wish to offer you, including sending you information promoting the products and services of such members or partners;
in order to fulfill your requests
to verify your identity (e.g., name, address, telephone number and date of birth, if applicable)
to verify creditworthiness;
to protect us against errors, fraud, theft and damage to our assets and property; and
to enable us to conduct our environmental, health and safety activities, including incident planning, response and investigation;
to enable us to comply with applicable legal, audit or regulatory requirements (for example, we may collect personal information to comply with obligations imposed on us by various regulatory boards or agencies to follow procedures required by such boards or agencies with respect to the provision of our products and services); and
any other reasonable business purpose to which you consent.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We only disclose personal information when necessary to fulfill the purposes identified in this Privacy Policy. We share your personal information with our employees, contractors, consultants and other parties (including other members of the company) who require such information to help us establish, maintain and manage our business relationship with you, including: third parties who provide services to us or on our behalf; third parties who collaborate with us in providing services to you; and, third parties whose services we use to perform our services. These service providers are contractually obligated to protect your personal information and may only use it to perform their services. We may process or store your personal information outside the United States or Canada at the facilities of a member of the Hydrofarm Group or at the facilities of a third party service provider.

In addition, your personal information may be disclosed:

As permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor not to disclose more personal information than is necessary under the circumstances;
to comply with valid legal process, such as search warrants, subpoenas or court orders;
as part of our regular reporting activities to other members of the Hydrofarm Group, including Hydrofarm subsidiaries outside the United States or Canada;
to protect the rights and property of the company (for example, to collect a debt or to protect us from fraud); or when we need the professional advice of financial or legal advisors; or
in an emergency that threatens the life, health or personal safety of an individual;
when personal information is available from a public source (for example, the telephone directory); or with your consent, when required by law.

In the event of a change of ownership or a grant of a security interest in all or part of the Hydrofarm Group or any subsidiary through, for example, a loan, a sale of assets or shares, or some other form of business combination, merger or joint venture or actions taken in anticipation of such events (e.g., due diligence on a transaction), provided that such party is bound by appropriate agreements or obligations and is obligated to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy.

ONLINE PRIVACY

If you provide us with your e-mail address, we may send you e-mail messages to keep you informed of our promotions and offers using your first and last name, zip code and e-mail address. In order to send you these e-mail messages, we may need to pass your name and contact information to our service providers who assist in the delivery of this e-mail service. We may also use third party companies to authenticate and validate your email address. You may opt-out of receiving future email communications by accessing the “manage your preferences or unsubscribe” link at the bottom of the email communication received and changing your preferences for the applicable content and/or email communication.

Our policies prohibit our service providers from using your information for any purpose other than what we tell them to do. Therefore, if you subscribe to our newsletters or other email communications, you should not receive unsolicited email from other companies. Please notify us at the address below if you believe this has occurred.

In addition to the information you provide to us, if you visit our websites, we may collect information during your visit using automatic data collection tools such as cookies, web beacons, embedded web links and other commonly used information collection tools that collect certain standard information that your web browser sends to our website during your visit. We may use this information to analyze customer activity, the composition of web traffic and to make improvements to its website. You can modify your browser settings to disable the use of cookies. However, please note that by doing so, some features of our websites may not function properly and you may be asked to re-enter your information more frequently.

YOUR CONSENT IS IMPORTANT TO US

It is important to us that when we collect, use or disclose your personal information we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, presumed (using an opt-out mechanism) or express. Express consent may be given orally, electronically or in writing. Implied consent is consent that can be reasonably inferred from your action or inaction. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time.

Normally, we will ask for your consent at the time we collect personal information. In certain circumstances, your consent may be obtained after collection but before we use or disclose your personal information. If we intend to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to inform you of that purpose prior to use or disclosure.

As described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

CHOICE / OPT-OUT

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by using the contact information below. In some circumstances, changing or withdrawing consent may severely limit our ability to provide products or services to you. All communications regarding such withdrawal or variation of consent must be in writing. We assume that, unless you communicate to us otherwise, by providing us with your personal information and by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

INTEREST-BASED ADVERTISING

We may engage in interest-based and behavioral advertising. We allow third party companies, such as advertising networks, to collect certain information when you visit our websites. This information is used to serve ads for our products or the products or services of other companies when you visit our websites or those of third parties. These third party companies use non-personally identifiable information (e.g., clickstream information, browser type, time and date, subject of advertisements clicked or hovered over, cookie and session ID) and personally identifiable information (e.g., static IP address) when you access the websites in order to provide you with advertisements about products and services that are likely to be of most interest to you, or advertising-related services, such as ad serving, reporting, attribution, analytics and market research. These third-party companies typically use a cookie, web beacon or other similar tracking technologies to collect this information.

For more information about interest-based advertising or opting out of interest-based advertising, please visit the Network Advertising Initiative website and the Digital Advertising Alliance website. The choices you make are browser and device specific. For information on how to opt out of Google Analytics, visit the Google Analytics website.

INFORMATION SECURITY

We strive to maintain physical, technical and procedural safeguards appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from being lost and from unauthorized access, copying, use, modification or disclosure. We will also use appropriate security measures when destroying personal information, and instead of destroying or deleting your personal information, we may anonymize it so that it cannot be associated with you or traced.

INTERNATIONAL TRANSFER

We are based in the United States. Information you provide to us or that we collect from you will be processed in the United States on servers located in the United States. If you are located outside the United States, please note that the personal information you provide to us will be treated in accordance with U.S. federal and state laws. We strive to implement appropriate safeguards to protect the privacy and security of your personal information and use it only as described in this Privacy Policy.

FOR CALIFORNIA RESIDENTS

THIS SECTION APPLIES TO RESIDENTS OF CALIFORNIA

Hydrofarm Group collects information only from any individual acting as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, individual business, non-profit institution or government agency in the context of providing or receiving a product or service from Hydrofarm Group.

The California Consumer Privacy Act of 2018 (“CCPA”) requires that certain information be provided to you as a California resident related to certain rights you have under the CCPA.

Right to opt-out.

We do not sell your personal information; however, we are required to inform you that you have the right to opt out of the sale of your personal information if we ever engage in such activity.

Right to Nondiscrimination

We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different fees or prices, including the use of discounts or penalties, or suggesting or providing you with a different level of service or quality of products. However, we may only charge you a different price or provide you with a different level or quality of products and services if the price or difference is directly related to the value provided to you by your personal information.

To submit a request to exercise any of your rights, please contact us at privacy@hydrofarm.com and add “CCPA REQUEST” in the subject line. We will evaluate the request and take action where necessary.

We will endeavor to respond to your request as soon as possible. If we are unable to respond to your request within 45 days, we will let you know that we may need more time (up to 90 days total).

FOR RESIDENTS OF CANADA

THIS SECTION APPLIES TO RESIDENTS OF CANADA

For residents of Canada, you may request to view the personal information we hold about you. If you would like to review, verify or correct your personal information, please contact us using the contact information below.

When you request access to your personal information, please note that we may ask you for specific information that will allow us to confirm your identity and your right of access, as well as to search for and provide you with the personal information we hold about you. We will make the requested information available to you within 30 business days, or notify you in writing of an extension when more time is required to fulfill the request. We may charge you a minimal fee for accessing your personal information, but we will inform you of any fees in advance.

Your right to access the personal information we hold about you is not absolute. There are instances where applicable law or regulatory requirements permit or require us to refuse to provide some or all of the personal information we hold about you. In addition, personal information may have been destroyed, erased or rendered anonymous in accordance with our record retention obligations and practices. In the event that we are unable to provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

PRIVACY OF CHILDREN

We do not knowingly collect or solicit any information from persons under the age of 18. In the event that we learn that we have inadvertently collected personal information from a person under the age of 18, we will delete that information. If you believe that we may have information from a person under the age of 18, please contact us at privacy@hydrofarm.com.

CONTACTING US

If you have any questions about this privacy policy, or have any questions or complaints about how we handle your personal information, please contact us by telephone, e-mail or postal mail:

HYDROFARM EUROPE
PQE empresarial sector p-9,
Building C Door 1
50639 Figueruelas, Zaragoza
+34.976.654.461

privacy@hydrofarm.com

REVISIONS TO THIS PRIVACY POLICY

From time to time we may make changes to this Privacy Policy to reflect changes in your legal or regulatory obligations or in the way we treat your personal information. We will post any revised version of this Privacy Policy on our website, www.hydrofarm.com, and on the websites of our North American subsidiaries and affiliated brands, and we encourage you to refer to it regularly. Any changes to this Privacy Policy will be effective upon posting.