OUR PRODUCTS
PRIVACY POLICY
Effective and last modified: January 1, 2023
This privacy policy has been drafted to explain how the companies of the Kao Americas Region (together “we,” “us,” or “our”) collect, use, disclose, and protect information that we collect about you, and to explain your rights with respect to that information. The Kao Americas Region companies covered by this Privacy Policy include:
This policy covers all personal information collected from and about our consumers, including when you use our websites. If in any case our privacy practices differ from those explained in this policy, we will let you know at the time we ask for or collect your information.
If you are a resident of California , Nevada, Canada, Australia, or New Zealand, additional location specific disclosures apply. Likewise, additional disclosures apply to California residents applying for jobs at one of the above companies.
1. Overview
We understand that your time is valuable. Therefore, we have set out some important highlights from the privacy policy in this Overview. This is simply an abbreviated summary, and does not contain all of the details of the policy. Please click the link corresponding to each section for the full details. We encourage you to read our full Privacy Policy, as it contains important information for you.
• What information we collect about you
• Identity or contact
• Payment and financial
• Transaction
• Technical
• Geolocation
• Profile
• Usage
• Marketing and communications
• Demographic and preferences
• Personal or physical characteristics
• User contributions and content
• Audio, visual and sensory
Anonymous data, or data for which you cannot be identified, is not considered personal information and may be used without restriction or limitation.
• Children’s Online Privacy
• How we collect your information
• Cookies and automatic data collection technologies
• You (e.g., when you communicate with us, complete a form, register an account, etc.)
• Our websites and emails (particularly via cookies and other automatic data collection tools)
• Our affiliates and third parties
• User contributions
• How we use your information
• Disclosure of your information
• Provide products and services
• Communicate with you
• Conduct marketing and promotions
• Administer programs
• Perform analytics and to personalize your experience
• Conduct security and fraud prevention
• Comply with our obligations and to protect our rights
• Perform core business functions
• Facilitate our actual or potential business relationship
• Accomplish another purpose
We may use non-personal or anonymized information for any purpose.
Attention: Customer Care
• Our affiliated companies
• Our service providers
• Our third-party partners
• Social media platforms and networks
• An acquiring or successor company
• Other third parties
We may also share your personal information with anyone to fulfill a purpose that:
• you provide it for;
• we indicate to you when you provide the information; or
• is with your consent.
We may share non-personal or anonymized information with anyone without restriction.
• Interest-Based Advertising
• Third Party Content, Apps, and Links
• Your Rights and Choices
If you rate a purchase, review our products, or upload content, or if you tag our brand and we reshare, any such information will become public information. We do not control how others may use, disclose or publish the content that you submit, and we are not responsible for the actions of third parties, even if they do not comply with our privacy policy, the law, or your intellectual property rights.
We do not control links to third-party websites that might be on our websites. Those websites have their own privacy policies and terms.
• Data Security and Risks
• Subscribe to or opt out of marketing communications
• Access, correct, update and delete your information
• Delete your user contributions
• Disable or refuse cookies and automatic data collection technologies
• Opt out of interest-based advertising
If you are a resident of California, Nevada, Canada, Australia or New Zealand, additional rights and choices may apply.
• Changes to Our Privacy Policy
The safety and security of your personal information also depends on you. Protect your passwords that we give you, and be careful what you post to the public areas of our websites.
• Contact Us
• For California Residents
To exercise your privacy rights, we have provided an online webform, as well as a toll-free phone number.
• For Nevada Residents
• For Canada Residents
• For Australia and New Zealand Residents
We may process, store, and transfer your personal information in and to a foreign country, which has different privacy laws that may or may not be as comprehensive as those of Canada. Your information may be accessible to courts, law enforcement and national security authorities in other countries.
We may store your personal information in the Province of Ontario in Canada, as well as the United States and Germany. Personal information will be accessible to our employees who have a “need to know” such information for the purposes described in this privacy policy.
To exercise your privacy rights, including to access or correct your personal information or to adjust your consent, please use one of the methods we have provided in the Contact Us section of this privacy policy.
• Job applicant privacy notice for California Residents
2. What information we collect about you
We may collect the following types of information about you:
Some of the information we collect about you may be personal information, or personal data, that can be used to identify you, including, for example, your name, email address, mailing address or delivery address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information.
Personal information does not include data where your identity has been removed so that we can no longer identify you (anonymous data). We may use anonymous data for any purpose.
3. Children’s Online Privacy
We do not direct our websites to minors, and we do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 13 without verification of consent by a parent or guardian, we will delete that information. If you believe we might have any information from or about a child under 13 please contact us as directed in the Contact Us section of this privacy policy.
4. How we collect your information
We collect information from and about you in the following ways:
5. Cookies and automatic data collection technologies
Our websites use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized service when you browse our website. It also allows us to improve our websites by enabling us to:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information, see the Interest-Based Advertising section of this privacy policy.
The technologies we use for this automatic data collection may include:
Depending on which website this notice is posted on, we may use Google Analytics to provide certain analytics services for us. More information about Google Analytics can be found in the Google Analytics Terms of Use and the Google Analytics Privacy Policy.
We may also use Meta Pixel from time to time. This tool allows us to understand and deliver ads and make them more relevant to you. The collected data remains anonymous and we cannot see the personal data of any individual user. However, the collected data is saved and processed by The Meta Companies (“Meta,” formerly known as Facebook). Meta may be able to connect the data with your Facebook account and use the data for their own advertising purposes (in accordance with Meta’s Data Use Policy found under https://www.facebook.com/about/privacy/). Meta has ultimate control of the information gathered through Meta Pixel.
6. How we use your information
We collect and use your information for various purposes, including the following:
If you do not want us to use your personal information for a purpose described above, or if you would like information on how to adjust your preferences, please see Your Rights and Choices below.
We may use non-personal or anonymized information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify, or allow for the identification of, any individuals to calculate the percentage of users accessing a feature on the website.
7. Disclosure of your information
We may share your personal information with:
We may also share your personal information with any of the above parties to fulfill any purpose that:
We may share non-personal or anonymized information with anyone without restriction.
8. Interest-Based Advertising
Some content or applications on our website may be served by third parties, including advertisers, ad networks, social media companies, content partners, or application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies (such as Meta Pixel) to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Our partners may use non-cookie technologies on which browser settings that block cookies might have no effect. Your browser may not permit you to block such technologies. For this reason, keep in mind that you can block the collection and use of information related to you by advertising companies for the purpose of serving interest-based advertising by visiting the following platforms of self-regulatory programs of which those companies are members:
9. Third Party Content, Apps, and Links
Some content or applications on our websites may be served by third parties, content providers and application providers including the following:
a. Plugins
We may make available the option for you to use “plugins” that are operated by social media companies. If you choose to use one of these plugins, then it may collect information about you and send it back to the social media company that owns it. This may happen even if you do not click on the plugin, if you are logged into the social media website that owns the plugin when you visit our website. Information collected by a plugin is subject to the privacy policy and terms of the social media company that makes it. If you do not want the social media company who owns a plugin to collect information about you when you visit our websites, sign out of the social media network before visiting. By interacting with a plugin when you are on our websites (for example, clicking the Facebook “Like” button), you are intentionally transferring information to that social media company. Further, if you are logged into a social media website when you visit our websites, then you are directing us to share your data with the social media company that owns the plugin.
We may use the following plugins:
b. User Contributions.
We may ask you to rate your purchases and/or review our products. We may post your ratings and reviews on our website. In addition, in some cases we may allow you to directly upload your own content to public areas of the website. If you tag our brand, we may like or reshare your social media posts. Any information you submit becomes public information, and we do not control how others may use or further disclose/publish the content you submit. We are not responsible for uses or further disclosure / publication by third parties, which may not comply with our privacy policy, the law, or your intellectual property rights.
c. Third-party links.
Our websites may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms.
10. Your Rights and Choices
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.
California Residents. If you are a resident of California, you may have additional personal rights and choices regarding your personal information. Please see the section below titled For California Residents for more information.
Nevada Residents. If you are a resident of Nevada, you may have additional personal rights and choices regarding your personal information. Please see the section below titled For Nevada Residents for more information.
Canada Residents. If you are resident of Canada, you may have additional personal rights and choices. Please see the section below titled For Canada Residents for more information.
Australia and New Zealand Residents. If you are a resident of Australia or New Zealand, you may have additional personal rights and choices regarding your personal information. Please see the section below titled For Australia and New Zealand Residents for more information.
11. Data Security and Risks
The security of your personal information is important to us. We use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse and unauthorized access, use, alteration or disclosure. Notwithstanding these measures, “perfect security” does not exist. In particular, we cannot guarantee the security of information communicated to us online or by email. It is possible that third parties may unlawfully intercept or access such information.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of our websites like message boards, which any website visitor can view. We cannot control the actions of other users of the website with whom you may choose to share information on public areas of our websites. Therefore, we cannot and do not guarantee that such information will not be viewed or copied by unauthorized persons. We are not responsible for uses or further disclosure or publication by third parties, even though it may not be consistent with our privacy policy.
12. Changes to our privacy policy
We may revise this privacy policy from time to time. The updated version of the policy will be available at this webpage.
13. Contact Us
A. Customer service inquiries.
If you have any customer service, retail, or press-related inquiries, please use the following relevant phone numbers and web or email addresses:
Brand
Phone Number
Web Link
ban
1-866-226-3363
https://www.feelbanfresh.com/contact-us/
Biore´
1-888-246-7311
https://www.biore.com/en-us/contact-us/
Curel
1-800-572-2931
https://www.curel.com/en-us/contact/
Goldwell
1-800-333-2442
https://www.goldwell.us/contact/
Jergens
1-800-742-8798
https://www.jergens.com/en-us/contact-us/
John Frieda
1-800-521-3189
https://www.johnfrieda.com/en-us/contact-us/
KMS
1-800-742-8798
https://www.kmshair.com/en-US/contact-us/
MyKirei by KAO
1-800-521-3189
https://www.mykirei.com/pages/contact-us/
Molton Brown
1-866-933-2344
uscustomerservice@moltonbrown.com
Wakati Hair
1-800-521-3189
https://www.wakatihair.com/contact
Oribe
1-888-ORIBE-99 (1-888 674-2399) or 1-877-670-6767 (if you in Canada)
https://www.oribe.com/oribestorefront/oribe/en/ /contact-us
You may write to Kao USA Inc. or Oribe Hair Care, LLC at: Kao USA Inc.
2535 Spring Grove Avenue
Cincinnati, OH 45214
You may write to Molton Brown USA LLC at: Molton Brown USA LLC
Attention: Customer Care
One Penn Plaza, Suite 4118
New York, NY 10119
You may write to Kao Canada Inc. at: Kao Canada Inc.
Attention: Customer Care
#2-75 Courtneypark Drive West
Mississauga, Ontario, L5W 0E3
You may write to Kao Australia Pty Limited at: Kao Australia Pty Limited
Attention: Customer Care
Level 2, 293 Camberwell Road
Camberwell, Victoria 3124
You may write to Kao New Zealand Limited at: Kao New Zealand Limited
Attention: Customer Care
Level 2, 109 Wellesley Street
Auckland 1010
B. To exercise your privacy rights.
To exercise privacy rights that you may have under this policy or applicable law, please submit your request via our Privacy Web Form, which can be accessed at this link. Alternatively, if you prefer, you may call us toll-free at 1-888-914-9661. If you have general questions, comments, complaints or requests regarding our compliance with this privacy policy or our handling of your personal information, please contact us by either of these means, or via the phone or web links provided in Section 13(A) above.
14. For California Residents
The California Consumer Privacy Act of 2018, as amended and expanded by the California Privacy Rights Act of 2020 (together known as the “CCPA”), requires us to provide the following notice to California residents.
This notice does not apply to information collected from California-based employees, job applicants, contractors, or similar individuals. Our California job applicant notice is available here.
A. Information We Collect
The information we collect and have collected about California residents in the last 12 months is described in the section “What information we collect” above and corresponds to the following categories of personal information under the CCPA:
In the last 12 months, we collected personal information from the sources described in the “How we collect your information” section above.Category
Description
Do We Collect?
A. Identifiers
Your name, alias, postal address, unique
personal identifier, online identifier, Internet
Protocol address, email address, account
name, or other similar identifiers. Yes
B. Personal information
described in subdivision (e) of
California Civil Code Section
1798.80 (known as the California
Customer Records Act) Your name, signature, address, telephone
number, credit or debit card number, bank
account number, or any other financial
information.
Some personal information included in this
category may overlap with other categories. Yes
C. Characteristics of protected
classifications under California or
federal law Age (40 years or older), race, color, ancestry,
national origin, citizenship, religion or creed,
marital status, medical condition, physical or
mental disability, sex (including gender,
gender identity, gender expression,
pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or
military status, genetic information (including
familial genetic information).Yes
D. Commercial information
Records of products or services purchased,
obtained, or considered, or other purchasing
or consuming histories or tendencies. Yes
E. Biometric information
Physiological, biological, or behavioral
characteristics, including information
pertaining to an individual’s DNA, that is used
or is intended to be used singly or in
combination with each other or with other
identifying data, to establish individual
identity. This may include things like
fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data.No
F. Internet or other electronic
network activity information Browsing history, search history, information
on a consumer's interaction with a website,
application, or advertisement.Yes
G. Geolocation data
Physical location or movements (for example,
to provide location-related services). Yes
H. Audio, electronic, visual,
thermal, olfactory, or similar
information Electronic or audio messages, recordings, and
sensory data.Yes
I. Professional or employment
related information Current or past job history, performance
information, wage and benefit information
(including retirement accounts, pensions,
insurance, beneficiary information, disability,
vacation, and leaves of absence), payroll
information, education, training, professional
memberships and certifications, references,
residency and work permit status, credit and
criminal background checks, the results of
drug and alcohol testing, vehicle registration,
driving history, emergency contact
information, other personal details included
in a resume, CV, or cover letter, and
information created, stored or transmitted
using our networks, devices, computers or
communications equipment. Yes
J. Education information that is
defined as information that is
not publicly available personally
identifiable information as
defined by the Family
Educational Rights and Privacy
Act (20 U.S.C. Section 1232g, 34
C.F.R. Part 99)) Non-public education records directly related
to a student maintained by an educational
institution or party acting on its behalf, such
as grades, transcripts, class lists, student
schedules, student identification codes,
student financial information, or student
disciplinary records. No
K. Inferences drawn from
personal information to create a
profile about the consumerInferences drawn from personal information
to create a profile reflecting a person's
preferences (including brand or product
preferences), characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes
L. Sensitive personal information
Under California law, “Sensitive Personal
.Information” refers to:
Personal information that reveals: Social
Security Number, driver’s license number,
state identification card, or passport number;
account log-in, financial account, debit card,
or credit card, in combination with any
required security or access code, password, or
credentials allowing access to an account;
geolocation; racial or ethical origin, religious
or philosophical beliefs, or union
membership; contents of mail, email, and text
messages; and genetic data.
Processing of biometric information for the
purpose of uniquely identifying a consumer.
Personal information collected and analyzed
concerning a consumer’s health.
Personal information collected and analyzed
concerning a consumer’s sex life or sexual orientation. Yes
B. Use of Personal Information
In the last 12 months, we used personal information for the business and commercial purposes described in the “How we use your information” section above.
C. Sharing of Personal Information
The business and commercial purposes that we have shared your personal information in the last 12
months are described above in Disclosure of your information. More specific information on that sharing
is as follows:
As described above, examples of business purposes include performing transactions, fulfilling orders, registering accounts, managing our relationship with you, and monitoring for security threats and fraud.
D. Your Rights Under the CCPA
o The categories of personal information we collected about you.
o The categories of sources for the personal information we collected about you.
o Our business or commercial purpose for collecting or selling that personal information.
o The categories of third parties with whom we share that personal information.
o If we sold or shared your personal information:
o Denying goods or services to the consumer.
o Charging different prices or rates for good or services, including through the use of discounts or other benefits or imposing penalties.o Providing a different level or quality of goods or services to the consumer.
o Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
o Retaliating against an employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.E. How to Exercise Your CCPA Rights
To exercise any of your rights under the CCPA (other than the “right of no retaliation,” which does not require any action from you), please use our Privacy Web Form, which can be accessed at this link. As an alternative, if you prefer, you may call us toll-free at 1-888-914-9661.
Please note that opting out of sales in the context of cookies will not stop us from advertising to you. We may still present contextual or other advertisements to you that do not rely on “sales” to our advertising partners
F. Who may submit requests?
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, you must provide the authorized agent with signed permission to make the request. If your authorized agent is a business entity, then the authorized agent must be registered with the California Secretary of State to conduct business in California. We may deny a request from an authorized agent that does not submit proof that it has been authorized to submit a request on your behalf. Further, before responding to a request from an authorized agent, we will still require you to (1) verify that you have provided the authorized agent permission to submit the request on your behalf; and (2) verify your identity directly with us
G. How often can you submit requests?
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
H. How we verify and respond to requests
Before fulfilling your request, we take steps to verify you are who you say you are or that you have authority to act upon someone else’s behalf. Therefore, upon receipt of your request, we will request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of the request you make, we may require you to verify your identity to either a reasonable degree of certainty or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us. In some cases, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request or that you are authorized to make the request on behalf of someone else.In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request and to locate relevant information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.We generally will only retain your personal information for so long as it is necessary to fulfill the purposes indicated in this Policy, unless a longer period of retention is required or permitted by law. We cannot delete personal information in those situations where our retention is necessary to comply with our legal obligations, resolve disputes, enforce agreements, prevent fraud or other deceptive or illegal activity, or for our own internal business purposes.
I. Response Timing and Format
We make a reasonable effort to respond to verifiable consumer requests within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing within 45 days of receiving your verifiable consumer request.Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity easily.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
J. Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Currently, we do not engage in this type of disclosure.
15. For Nevada Residents
Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services.
We do not currently sell covered information, as “sale” is defined under Nevada law, and we do not have plans to sell this information.
16. For Canada Residents
We comply with applicable Canadian privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act (PIPEDA), in connection with processing Canadian personal information.
We will only use personal information for the purposes described in this policy unless consent is obtained or use is otherwise permitted or required by law.
Transferring Your Personal Information Outside Canada
Personal information may be transferred to third parties, including affiliates and service providers, as described in the Disclosure of your information section.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country
You are welcome to contact us if you have questions regarding the collection, use, disclosure or storage of personal information by our service providers and affiliates outside Canada, and/or to obtain access to written information about our policies and practices with respect to service providers (including affiliates) outside Canada. For questions about our privacy practices, please contact us as directed in the Contact Us section of this policy.
By submitting your personal information or engaging with the website, you consent to the transfer, storage, and processing of such information outside of Canada.
Data Retention
Your personal information will be kept in the Province of Ontario in Canada, and may also be held in the United States and Germany. Personal information will be accessible to our employees who have a “need to know” such information for the purposes described in this privacy policy, which may include personnel from our Sales, Marketing, Customer Care, Finance and Accounting, Information Technology, Human Resources, and Legal Departments, as well as personnel supporting business administration or operations.
Except as otherwise permitted or required by applicable law or regulation, we will generally only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and/or for the purposes of satisfying any legal, accounting, or reporting requirements. Please note, however, that we may retain personal information in those situations where it is necessary to comply with our legal obligations, resolve disputes, enforce agreements, prevent fraud or other deceptive or illegal activity, or for our own internal business purposes. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you, either directly or indirectly, alone or in combination with any other information. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Accessing and Correcting Your Personal Information
By law you have the right to request access to and to correct or rectify the personal information that we hold about you, subject to certain exceptions as required or permitted by applicable law.You can review and change your personal information by logging into your account and visiting the pages that correspond to the information you want to review and change.If you want to access, review, verify, correct, rectify, update, or withdraw consent to the collection, use or disclosure of your personal information you may also contact Kao USA as directed in the Contact Us section of this policy to make such a request
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.We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions may include (without limitation):
If you are not satisfied with our response, please contact us as described in the Contact Us section of this policy.
17. For Australia and New Zealand Residents
In Australia, we comply with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth). In New Zealand, we comply with the Information Privacy Principles (IPPs) as contained in the Privacy Act 2000 (NZ).
It may be possible for you to deal with us on an anonymous basis (ie, providing no name or personally identifying details), or on a pseudonymous basis (ie, providing a name or descriptor that is different to your true identity). However, there will be some scenarios where the use of your true identity is a legal requirement (for example, to verify consumer identity, to process and collect payments on transactions, etc.), or where anonymity or pseudonymity will be impracticable.
If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to fulfill the business purposes that we have identified in this policy. It may also impact your interactions with our various products, services and platforms. For example, you may be unable to access certain portions of our websites, or you may experience certain limitations in the scope of interactions and services that we can provide.
In the case of “sensitive” personal information (which includes, without limitation, racial and ethnic origin, sexual orientation, health information, etc.), we will comply with the applicable laws of Australia and New Zealand, and will obtain your consent to collection to the extent required by law, and will only collect or use such sensitive personal information to the extent it is necessary for one or more of our functions or activities.
We make a reasonable effort to respond to verified requests within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing within 45 days of receiving your verified request.
Our business is affiliated with other businesses, organisations and people located overseas. In the course of doing business with you, we are likely to disclose some of your personal information to these overseas recipients. We typically only do so where it is necessary to complete the transaction you have entered into, or you have provided your consent, or it is permitted by the relevant privacy and data protection laws in your jurisdiction.We also take reasonable steps to ensure that the overseas recipients are bound by privacy and data protection obligations. Our corporate group affiliates and external service providers are located in Australia, New Zealand, the United States of America, Canada, Germany, the United Kingdom, Spain, Switzerland, Italy, Finland, Norway, Sweden, Denmark, the Netherlands, Belgium, the Czech Republic, France, and Austria.
Job Applicant Privacy Notice for California Residents
Effective Date: January 1, 2023
Last Updated on: January 1, 2023
1. Introduction
This Privacy Notice for California Residents describes how the Kao Americas Region companies (named at the beginning of our Privacy Policy)(“we,” “our,” or “us”) collect and use personal information about you if you are a natural person applying for a job at one of our companies and are a California resident (“Covered Person”).
We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended and expanded by the California Privacy Rights Act of 2020 (CPRA), and as may be further amended, replaced, or superseded, as well as any implementing regulations.
Any terms defined in the CCPA have the same meaning when used in this Notice.
This Privacy Notice describes the categories of personal information that we collect from Covered Persons and the purposes for which the categories of personal information may be used.
2. Categories of Personal Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Covered Person or device (“personal information”). However, personal information does not include:
Specifically, we collect the following categories of personal information:
Category
Description
Do we collect this information?
A. Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
YES
B. Personal information described in subdivision (e) of California Civil Code Section 1798.80 (known as the California Customer Records Act)
Your name, signature, address, telephone number, credit or debit card number, bank account number, or any other financial information.
Some personal information included in this category may overlap with other categories.YES
C. Characteristics of protected classifications under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial Information
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
E. Biometric Information
Physiological, biological, or behavioral characteristics, including information pertaining to an individual’s DNA, that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. This may include things like fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F.Internet or other electronic network activity information
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
NO
G. Geolocation Data
Physical location or movements (for example, to provide location-related services).
YES
H. Audio, electronic, visual, thermal, olfactory, or similar information
Electronic or audio messages, recordings, and sensory data.
YES
I. Professional or employment related information
Current or past job history, performance information, wage and benefit information (including retirement accounts, pensions, insurance, beneficiary information, disability, vacation, and leaves of absence), payroll information, education, training, professional memberships and certifications, references, residency and work permit status, credit and criminal background checks, the results of drug and alcohol testing, vehicle registration, driving history, emergency contact information, other personal details included in a resume, CV, or cover letter, and information created, stored or transmitted using our networks, devices, computers or communications equipment.
YES
J. Education information that is defined as information that is not publicly available personally identifiable information as defined by the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Non-public education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from personal information to create a profile about the consumer
Inferences drawn from personal information to create a profile reflecting a person's preferences (including brand or product preferences), characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
L. Sensitive personal information
Under California law, “Sensitive Personal Information” refers to: Personal information that reveals: Social Security Number, driver’s license number, state identification card, or passport number; account log-in, financial account, debit card, or credit card, in combination with any required security or access code, password, or credentials allowing access to an account; geolocation; racial or ethical origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages; and genetic data. Processing of biometric information for the purpose of uniquely identifying a consumer. Personal information collected and analyzed concerning a consumer’s health. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
YES
3. Why We Collect Your Personal Information
We may use the above categories of personal information we collect about you, for one or more of the following purposes:
4. Contact Us
For questions or concerns about our privacy policy and practices, you can contact us at the method set forth below.
Phone: 1-888-914-9661 Web: Kao Privacy Web Form

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