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Online Privacy Policy Statement

Last revised: June 1, 2022

This Privacy Policy (the “Privacy Policy”) informs the users of the Salon Alliance Rewards Program and the SalonShop Portal (collectively, the “Website”) about how Kao Canada Inc. ("Kao Company" or "we", "our" and similar terms) collects, uses, shares and otherwise processes (collectively, “Process”, “Processing”, “Processes” or “Processed”) their personal information in connection with their usage of Website.

Please note that this Privacy Policy does not apply to any other websites, mobile apps or personal information Processing activities of Kao Company or its parent, affiliates or subsidiaries (together, “Kao Group”), except as specifically listed above.

WEBSITE PRIVACY POLICY – SUMMARY OF KEY POINTS

Kao Company understands that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Policy. You can obtain more information about how we Process and protect your personal information by reviewing our full Privacy Policy or clicking on the links provided below. We encourage you to read our full Privacy Policy, as it contains important information for you.

What personal information do we collect?

Why do we collect personal information and how is it used?

Is personal information shared or disclosed?

What are the risks?

What else should you know?

 

WEBSITE PRIVACY POLICY – FULL POLICY

  1. Categories of Personal information and Processing Purposes - What personal information do we Process about you and why?

We collect certain information from and about you when you create a Website Account, use your account to purchase products, participate in the Salon Alliance Rewards Programs, complete our surveys, post on our message boards, and/or communicate with us regarding your Website Account. As further explained below, we use this information to create and manage your account, facilitate and complete your transactions (e.g., purchases or reward redemption), provide customer service, for marketing purposes, to evaluate and improve our products and services, to send you emails and newsletters, and for other purposes as permitted or required by applicable law. 

In addition, when you use the Website, certain information is automatically collected by cookies and other tracking technologies as described in Section 6 below (“Cookies and other tracking technologies”).

We may also combine the information that we collect through or in connection with the Website with other information we hold about you, your salon and/or your customer account, for the purposes described above.   

1.1         Account Creation and Management

If you create an account for our Website (“Website Account”), we collect and Process the following information about you: first and last name, country, email address, telephone number, selected password for your Website Account, answers to security questions, member type, salon information (i.e., your salon name, postal address and phone number), distributor name and account number (where applicable), account number, payment details (including card type, cardholder name, expiration date, card number, security code, billing address and phone number), invoicing and delivery addresses, photographs (i.e., if you upload profile pictures), and your request to receive marketing materials (voluntary).  This information will be collected from you by email when you submit a registration request to one of our brand executives or sales representatives, or when you complete our online registration process.

We process such personal information for the purposes of account creation and administration (including to send you emails regarding your Website Account), verification of identity and eligibility to use the Website, answering your queries or information requests about your Website Account, and providing desired products or services (including to autofill relevant fields when you purchase a product on the Website in order to save you time).

1.2         Product Orders

If you use the Website to shop for and order products, we collect and Process the following personal information about you: name, gender (salutation), delivery address, email address, telephone number, payment details (including card type, cardholder name, expiration date, card number, security code, billing address and phone number), type and amount of product, purchase price, order date, order status, order history, account adjustments and product returns, “favorites” list (including name and date that items were added to such list), and customer care requests.

We Process such personal information for the purposes of carrying out the contractual relationship, fulfilling your product order and providing customer care services. We may also use such information to communicate with you.  For example, we will send emails to confirm your orders, and may notify you by email when an out-of-stock item becomes available if you have requested such notifications.

 

1.3         The Salon Alliance Rewards Program

If you register for a Website Account to participate in our Salon Alliance Rewards Program, we Process the following information about you: first and last name, profession, bio, email address, telephone number, preferences regarding marketing materials (voluntary), salon information (i.e., your salon name and type, postal address, email address, phone number and web address), distributor name and account number (where applicable), account number, reward order history, and choices regarding program participation.  

We Process such personal information for the purposes of carrying out and fulfilling your transactions (i.e., when you redeem rewards) and providing customer care services.

If you choose to purchase additional points, your payment details will also be Processed by PayPal. We do not have access to the information that is Processed by PayPal.

 

1.4         Surveys & Other Commentary

If you participate in a survey, we collect your answers to survey questions, which are associated with your Salon Alliance Account information. We Process such information for the purposes of understanding your views and preferences regarding products sold by Kao Group, as well as analyzing and aggregating such information together with information obtained from other survey participants. You will also be awarded points based on the surveys you complete when you participate in the Salon Alliance Rewards Program.

If you participate on our message boards (such as “Join the Conversation”), we also collect and share your social media handle and any information that you post on the site (including any personal information that you include in your post).   

Responding to surveys and participating on our message boards is entirely voluntary.

 

1.5         Customer Service

If you communicate with us using the “Contact Us” features on the Website, or contact us by phone or email regarding a customer service matter, we (or our service provider) will collect your name, email address, phone number, customer number, salon name, mailing address and/or the reason for your enquiry, as well as the contents of your messages and other communications.  Calls to customer service may also be recorded.

We Process such information to respond to your communications, address your questions and concerns, and otherwise provide or improve our customer service. 

 

1.6         Marketing and Improving Our Products and Services

We may also use the information that we collect about you (as described in Sections 1.1 to 1.4 above), as well as information that is collected automatically when you use the Website (see Section 6 below – “Cookies and other tracking technologies”) to improve the Website (including based on usage patterns) and our other products and services, provide recommendations regarding products you may wish to purchase on the Website, and provide you with marketing materials to the extent permitted by applicable law. You may contact us at any time if you do not want your information to be used for marketing or other non-essential purposes.

 

1.7         Other Purposes Permitted or Required by Law

We may collect and use your personal information for other purposes with your knowledge and consent (express or implied, as permitted by applicable law).

We may also use the information that we collect about you (as described in Sections 1.1 to 1.4 above) for other purposes, as permitted or required by law. Depending upon applicable law, such purposes may include: facilitating a business transaction, such as the sale of all or part of our business, compliance with legal obligations (including record retention obligations or responding to a court order, warrant or subpoena), defending, establishing and exercising legal claims, collecting a debt, detecting and preventing fraud, and for technical administration and security.

 

  1. Processing Basis and Consequences - What is the legal justification for processing your personal information and what happens if you choose not to provide it?

We rely on your consent to Process your personal information, subject to certain exceptions as permitted by applicable law.  Your consent may be express or implied (as permitted by applicable law), including when you accept this Privacy Policy in connection with creating your Website Account, ordering products or redeeming rewards.  In some cases, subject to applicable laws, your consent may be deemed when you voluntarily provide us with your information for a specific purpose, and we only Process such information for that purpose.  

The provision of some personal information is necessary to enter into a contract with us or to receive our services/products/rewards as requested by you. The provision of additional personal information is voluntary for you.

Not providing your personal information may result in disadvantages for you, for example, you may not be able to order products or redeem awards.

  1. Categories of Recipients and International Transfers - Who do we share your personal information with and where are they located?

Depending on the categories of personal information and the purposes for which the personal information has been collected, different internal departments within the Kao Company may receive your personal information. In general, such information may be accessible to data specialists, our Master Data Team and our Salon Alliance Team, as well as eCommerce, sales, customer service, account managers, brand executives / representatives and IT employees who have a need to access such information to perform their duties. For example, our IT department may have access to your account data, and our eCommerce and sales departments may have access to your Website Account data or data relating to product orders. Moreover, other departments within the Kao Company may have access to certain personal information about you on a need-to-know basis, such as the legal department, the finance department or internal auditing.

We may transfer your personal information to third parties for the purposes described in Section 1 above as, “Categories of Personal information and Processing Purposes - What personal information do we Process about you and why?”, follows:

In addition, if you purchase points for the purposes of redeeming any reward(s) in connection with the Salon Alliance Rewards Program, your payment will be processed by PayPal. Please note that Kao Company does not have access to, or control over, any information that you submit to PayPal, and such information will be Processed in accordance with PayPal’s privacy policies and practices, which may differ from this Privacy Policy.

Kao Company reserves the right to add or change service providers at any time, in its sole and absolute discretion, without notice to Website users.

We will not disclose your personal information to third parties for their own advertising or marketing purposes without your permission.

International transfers. Kao Company and its affiliates and service providers transfer and store the personal information that we collect or receive in countries other than Canada, including in the United States of America and Germany.  We will implement reasonable measures to ensure that transfers out of Canada are adequately protected as required by applicable data protection law. However, such information may be accessible to courts, law enforcement and national authorities in such other countries. You may contact our us, as described below under Section 7, “Questions and Contact Information”, if you have questions about the collection, use, disclosure or storage of personal information by our service providers and affiliates outside Canada, or to obtain access to written information about our policies and practices with respect to such service providers and affiliates outside Canada.

 

  1. Risks and Consequences

We implement safeguards to protect the information you provide to us through or in connection with Website, including masking and/or tokenization of payment information, regular patching of security vulnerabilities, and limiting access to personal information on a “need to know” basis.  Although we take the above steps to safeguard the personal information under our control, "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 Website, you are responsible for keeping your password confidential. We ask you not to share your password with anyone.

Our websites may allow you to upload your own content to public areas of the website (e.g., posting on message boards such as “Join the Conversation”). 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. Therefore, we urge you to take care when providing information in public areas of our websites, which any website visitor can view.

  1. Your Rights - What rights do you have and how can you assert your rights?

Depending on the jurisdiction where you are located, you may have certain rights under applicable privacy and data protection legislation.  Such rights may include:

To exercise your rights, please contact us as stated under Section 7 below, “Questions and Contact Information”. You may also have the right to lodge a complaint with the relevant privacy commissioner.

 

  1. Cookies and other tracking technologies

A cookie is a small text file a web portal installs on your computer, tablet or smartphone when you visit the portal. Cookies can help us in many ways, for example they make it possible for the portal to remember certain entries and settings (e.g. login info, language, font size and other display preferences) for a specific period of time so you do not have to re-enter this information every time you visit and navigate the portal; for example, by allowing us to tailor a website to better match your interests or to store your password to save you having to re-enter it each time. Furthermore, when you visit our Website you may notice some cookies that aren't related to us. If you go on to a web page that contains embedded content, you may be sent cookies from these websites. We don't control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.

Here's a list of the cookies we use and what we use them for.

Kao or its service provider that administers Website uses cookies that facilitate the functioning of our site (i.e., functional and strictly necessary cookies), including to record your preferences, protect Kao’s font from being used by other websites, and facilitate the functioning of order forms and “Contact Us” features on Website. These cookies collect information such as your IP address, session ID, browser type, origination and destination domains, and information regarding your use of Website.

When you visit our website, you may notice some cookies that aren't related to Kao. If you go on to a web page that contains embedded content, you may be sent cookies from these websites. We don't control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

Google Analytics provides us with certain data regarding the demographics of Website users as well as statistical data about the number of people using Website. The data collected by Google Analytics on Website includes data related to your device/browser, your IP address, pages viewed, time per page, links clicked, and searches on Website. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245 . You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout/  or downloading the Google Analytics Opt-out Browser Add-on (located at https://support.google.com/analytics/answer/181881?hl=en).

Fresh Relevance uses performance cookies and other tracking technologies on Website to provide us with data analytics and personalization solutions, including to evaluate your use of Website and allow us to provide recommendations regarding products that may be of interest to you.  For more information see https://www.freshrelevance.com/legal/privacy-policy.

These cookies are used by Instagram as soon as the Instagram plugin has been activated on our website. For more information on the type, use and purpose of these cookies, please click the following link: https://www.instagram.com/about/legal/privacy/#  

These cookies are used by Pinterest as soon as the Pinterest plugin has been activated on our website. For more information on the type, use and purpose of these cookies, please click the following link: https://about.pinterest.com/en/privacy-policy  

These cookies are used by YouTube and/or Google as soon as a video has been integrated on a site and/or has been played. For more information on the type, use and purpose of the cookies, please click on the following link: https://www.google.com/intl/en/policies/privacy/  

These cookies are used by Facebook as soon as the Facebook plugin has been activated on our website. For more information on the type, use and purpose of these cookies, please click the following link: https://www.facebook.com/policies/cookies/  

These cookies are used by Twitter as soon as the Twitter plugin has been activated on our website. For more information on the type, use and purpose of these cookies, please click the following link: https://www.twitter.com/privacy  

You can manage and/or delete all of the cookies stored on your computer and you can set up most browsers in such a manner that the archiving of cookies is prevented in the first place. However, if you do this, you may have to manually adjust some settings every time you visit Website and/or some functions of our sites may not operate.

 

  1. Questions and Contact Information

If you have any questions about this Privacy Policy or Kao Company’s collection of your personal information (including if you have questions about the collection, use, disclosure or storage of personal information by our service providers and affiliates outside Canada, or wish to obtain access to written information about our policies and practices with respect to such service providers and affiliates), or if you want to exercise your rights as described above in Section 5, “Your Rights - What rights do you have and how can you assert your rights?”, please call us at 1-888-914-9661, or you may click on the following link and complete the related web form: Kao Privacy Policy 

 

  1. Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements, and/or to reflect changes to our practices. We will notify you of any such changes, including when they will take effect, by updating the "Last revised" date above or as otherwise required by applicable law. Your continued use of our Website after any such updates take effect will constitute acceptance of those changes, where permitted by applicable law.  Alternatively, we will notify you directly of a significant change and/or obtain you express consent if/when required by applicable law. If you do not accept updates to this Privacy Policy, you should stop using our Website.