Last revised March, 16, 2018
Note that other Kao Group websites or mobile apps may be governed by other privacy policies.
1. Categories of Personal Data and Processing Purposes - What personal data do we process about you and why?
You may use the Website without providing any personal data about you. In this case, we will collect only the following metadata that result from your usage of the Website: browser type and version, operating system and interface, website from which you are visiting us (referrer URL), webpage(s) you are visiting on our Website, date and time of accessing our Website, and internet protocol (IP) address.
Your IP address will be used to enable your access to our Website. Once the IP address is no longer necessary for this purpose, we will shorten your IP address by removing the last octet of your IP address. The metadata, including the shortened IP address, will be used to improve the quality and services of our Website and services by analysing the usage behaviour of our users.
To create an account in our Website, you will be asked to provide the following personal data about you: name, gender (salutation), email address. We process such personal data for purposes of account administration, answering your queries or information requests, providing desired products or services, providing you with marketing materials to the extent permitted by applicable law, analysing your interests for marketing purposes, improving our Website according to usage patterns, and for technical administration or other purposes to which you have agreed.
2. Processing Basis and Consequences - What is the legal justification for processing your personal data and what happens if you choose not to provide it?
We rely on the following legal grounds for the collection, processing, and use of your personal data:
- the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data, in particular if you are a child; such legitimate interests are the fulfilment of the processing purposes set out above in Section 1, in particular to provide the most suitable information to each website user profile.
The provision of your personal data is not required by a statutory or contractual obligation. The provision of your personal data is not necessary to enter into a contract with us or to receive our services/products as requested by you. The provision of your personal data is voluntary for you.
Not providing your personal data may result in disadvantages for you--for example, you may not be able to receive certain information in your email or you may not access to a private area where the technical information of our products is displayed. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.
3. Categories of Recipients and International Transfers - Who do we transfer your personal data to and where are they located?
We may transfer your personal data to third parties for the processing purposes described above as follows:
- With data processors: Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data under appropriate instructions ("Processors") as necessary for the processing purposes described above, such as Website marketing service providers, IT support service providers, and other service providers who support us in maintaining our commercial relationship with you. The Processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data, and to process the personal data only as instructed.
International transfers. The personal data that we collect or receive about you may be transferred to and processed by recipients that are located inside or outside the European Economic Area ("EEA"). For recipients located outside of the EEA, some are certified under the EU-U.S. Privacy Shield and others are located in countries with adequacy decisions and, in each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective. Other recipients might be located in countries which do not adduce an adequate level of protection from a European data protection law perspective. We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, we will base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved codes of conduct together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient. You can ask for a copy of such appropriate safeguards by contacting us as set out in Section 7 below.
4. Retention Period - How long do we keep your personal data?
Your personal data will be retained as long as necessary to provide you with the services and products requested. Once you request your account to be deleted or otherwise ended your relationship with us, we will remove your personal data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which the Kao Company is subject--e.g., taxation purposes).
We may retain your contact details and interests in our products or services for a longer period of time if the Kao Company is allowed to send you marketing materials. Also, we may be required by applicable law to retain certain of your personal data for a period of 10 years after the relevant taxation year. We may also retain your personal data after the termination of the contractual relationship if your personal data are necessary to comply with other applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need to know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship.
5. Your Rights - What rights do you have and how can you assert your rights?
Right to withdraw your consent: If you have declared your consent regarding certain collecting, processing and use of your personal data (in particular, regarding the receipt of direct marketing communication via email, SMS/WhatsApp, and telephone), you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Please contact us as stated in Section 7 below to withdraw your consent. [Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with the basic tariffs.]
Additional data privacy rights: Pursuant to applicable data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; and/or (vi) object to the processing of your personal data (including objection to profiling).
Please note that these aforementioned rights might be limited under the applicable local data protection law. Below please find further information on your rights to the extent that the GDPR applies:
- Right to request access to your personal data: You may have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data. This access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
- Right to request rectification: You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to request erasure (right to be forgotten): Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
- Right to request restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In such case, the respective data will be marked and may only be processed by us for certain purposes.
- Right to request data portability: Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
- Right to object:
Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. Such right to object may especially apply if we collect and process your personal data for profiling purposes in order to better understand your interests in our products and services or for direct marketing.
If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. You may exercise this right by contacting us as stated in Section 7 below.
Such a right to object may, in particular, not exist if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
If you no longer want to receive direct marketing via email, SMS/MMS, fax, and telephone, you need to withdraw your consent as explained above.
To exercise your rights, please contact us as stated under Section 7 below. You also have the right to lodge a complaint with the competent data protection supervisory authority.
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7. Questions and Contact Information