Last Updated: January 2023
By using the Services you understand that you are sharing information with both Colgate and Kolibree.
PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF DATA FROM U.S. CHILDREN UNDER AGE 13 AND CHILDREN OUTSIDE THE U.S. UNDER AGE 16.
“Personal Data” is data that identifies you as an individual or relates to an identifiable individual, such as:
Collection of Personal Data
We and our service providers collect Personal Data in a variety of ways, including:
Data the App Uses in Real-Time
The technology used to evaluate your tooth brushing, which includes algorithms that analyze your face and your brushing technique, is run in real time on your device (and thus is not collected or captured by Colgate). Colgate does not collect this information from your device or access it on your device. Nor does Colgate use this technology to identify you.
Use of Personal Data
We and our service providers use Personal Data for legitimate business purposes, including:
Disclosure of Personal Data
We disclose Personal Data:
Other Uses and Disclosures
We also may use and disclose your Personal Data as necessary or appropriate when we have a legal obligation or legitimate interest to do so:
Collection of Other Data
We and our service providers may collect Other Data in a variety of ways, including:
Uses and Disclosures of Other Data
We may use and disclose Other Data for any purpose, except where we are prohibited from doing so under applicable law. In some instances, we may combine Other Data with Personal Data. If we do, we will treat the combined data as Personal Data as long as it is combined.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our respective organizations. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Data
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may opt-out from:
How you can access, change, or delete your Personal Data
You may delete your account and update or correct certain of your Personal Data through your Services account settings.
You may also contact Colgate at firstname.lastname@example.org and Kolibree at email@example.com if you would like to request to review, correct, update, suppress, restrict, or delete Personal Data that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law). We will each respond to your request consistent with applicable law.
In your request, please make clear what Personal Data you would like to have changed. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
THIRD PARTY SERVICES
In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, Blackberry, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with the Services.
THIRD PARTY PAYMENT SERVICE
OUR COLLECTION OF PERSONAL DATA FROM CHILDREN
The Site is not directed to children, and we do not knowingly collect Personal Data from children on the Site.
When an App user who is under the age of 13 (for U.S. users) or 16 (for non-U.S. users) seeks to create an account (a “child accountholder”), we collect his or her first name and the email address of his or her parent or guardian, in order to seek the consent of the parent or guardian to our collection of Personal Data from the child. We and our service providers also collect the data described above, under “Other Data,” from child accountholders. If we receive the consent of the child’s parent or guardian, then we may also collect the child’s email address and profile photo.
We use and disclose a child accountholder’s Personal Data as described above, under “Use of Personal Data” and “Disclosure of Personal Data.”
If you would like to review the Personal Data we have collected from your child, or if you would like to ask us to make no further use of, or delete, the Personal Data we have collected from your child, please contact us as described in the “Contacting Us” section, below. In your request, please include your name and email address, and specify the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your data will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.
Additional Information Regarding the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You may obtain a copy of these measures here.
Unless we specifically request it, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
YOUR CALIFORNIA AND OTHER STATE PRIVACY RIGHTS
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, the law in your state provides you with the following rights with respect to your Personal Data:
Your California, Colorado, Connecticut, Utah, and Virginia Privacy Rights
California Business Contact Information
If you are a California resident and we receive your Personal Data in the form of contact details from business events, for example as part of a business appointment (e.g., by exchanging business cards) or as part of any other form of collaboration, we may use your contact and business details to maintain our business contacts. For this purpose, we may transfer your contact details to our internal database. Pursuant to the CCPA, you have privacy rights with respect to your business contact Personal Information.
The processing activity may include the following categories of Personal Information:
This data processing is based on our legitimate business interests. We have a legitimate economic interest in maintaining contacts beyond the initial context and in using them to establish and develop a business relationship and to remain in contact with the parties concerned.
Such business contacts could also be processed in our email communications with you and then kept in typical business software, either centrally or on the electronic devices of our employees.
California law provides you with the following rights with respect to your Personal Data:
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Data we have collected about you by accessing our Consumer Affairs page by clicking here or by contacting our Toll-Free Telephone Number at 1-800-468-6502.
We will respond to your request in compliance with the requirements of your state’s applicable laws. Please note that we are only required to honor California requests to know twice in a 12-month period.
Verification of Your Identity
When you exercise these rights and submit a request to us, we will verify your identity by asking you to provide us with additional information such as your email address, order numbers of previous orders of our products and services. We also may use a third-party verification provider to verify your identity.
Residents of Colorado, Connecticut, and Virginia may appeal a decision we have made regarding their requests by calling us at 1-800-468-6502 or by using the form available on our website. We will respond to appeals from Virginia and Connecticut residents within 60 days. We will respond to appeals from Colorado residents within 45 days.
If you make a request under the CCPA, we will not discriminate against you in any way. For example, we will not deny you discounts or other benefits or impose penalties on you, or provide you with or suggest that you will receive a different level or quality of benefits or services.
You may permit an authorized agent to submit a request to know or to delete your Personal Data. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Data.
We generally do not use automated decision-making technology, as that term is defined by State Privacy Laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.
300 Park Avenue
New York, NY 10022
United States of America
Because email communications are not always secure, please do not include credit card or other sensitive data in your emails to us.
ADDITIONAL INFORMATION FOR THE EEA
You also may:
HEC Harald Eul Consulting GmbH
Datenschutz + Datensicherheit
Auf der Hoehe 34
Tel.: +49 2232 1885-210
Fax: +49 2232 200-884
Cabinet Dézavelle-Livowsky & Associés
11 rue Théodule Ribot
Tel.: +33 1 4227 7349
Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.
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