COLGATE CONNECT PRIVACY POLICY AND TERMS OF USE

PRIVACY POLICY

Effective Date: January 9, 2018

Colgate-Palmolive Company (“Colgate”), which offers the Colgate Connect E1 Smart Toothbrush (the “Product”), is committed to protecting the privacy and security of your personal information.  This Colgate Connect Privacy Policy (the “Privacy Policy”) describes how we may collect, use and disclose your personal information when you visit the Colgate Connect website at www.colgate.com/connect (the “Website”), use the Product, or use the Colgate Connect mobile application (the “Mobile App”). The Website, the Product and the Mobile App are referred to collectively as the “Services.”  This Colgate Connect Privacy Policy supplements the terms of the Colgate Privacy Policy (the “Colgate Privacy Policy”), and applies solely to the information that we collect through the Services.  This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business relationship not handled through the Website, the Product or the Mobile App).

Relationship with Kolibree

The Product is powered by Kolibree SAS and its subsidiaries (“Kolibree”).  Colgate is a licensee of Kolibree and has also entered into a development agreement with Kolibree.  Under this arrangement, Colgate and Kolibree jointly own any data generated by usage of the Kolibree smart electric toothbrush and the Mobile App.  Kolibree has the same rights to use and disclose your PII as Colgate, as described in this Privacy Policy.  The terms “we,” “our” or “us,” when used in this Privacy Policy, shall refer collectively to Kolibree and Colgate.

Acceptance of Privacy Policy

By using the Website, the Product or the Mobile App, you signify your acceptance of this Colgate Connect Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not use the Services.  Your continued use of the Website, the Product or the Mobile App following the posting of changes to this Privacy Policy will mean that you accept those changes.

Personal Information We Collect

Through the Website.  Colgate collects your personally identifiable information (“PII”) through the Website when you choose to provide such information, such as when you (i) submit information through the “Contact” page of the Website, where you must provide your email address, (ii) purchase or reserve a Product using the Website’s Shopping Cart, (iii) sign up for our newsletter, (iv) chat online with a customer service representative, (v) post a product review, or (vi) post a comment in response to a blog post.  Colgate also collects your IP address and web log data.  Please note that all payments are processed via third party payment processors, and we do not store any of your credit card information.  Please be careful not to provide any personal information on any public sections of the Website.

Through the Smart Toothbrush and Mobile App.  The Colgate Connect E1 Smart Toothbrush, when combined with the Mobile App, collects your PII to (i) create a new account, for which you must provide information such as your name, gender, year of birth and handedness, and (ii) use the Product, which, depending upon the model, may collect information such as time spent brushing, areas of the mouth brushed, the position of the toothbrush during brushing, and information about your mobile device including device ID and your location.

Use of Personal Information

We will use your PII only (i) to operate the Website and Mobile App, (ii) to provide the Product and related services to you, (iii) to address your requests for information, products or services, (iv) for research purposes, and (v) for product development.  If you create an account and provide your email address, we may send you administrative and promotional emails. Where required in the relevant jurisdiction, we will obtain your consent before sending you promotional emails.  If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email.

Disclosure of Personal Information

Colgate and Kolibree will not sell, rent, license, or trade your PII with third parties for their own direct marketing use unless we receive your express consent to do so.  Unless you give us permission to do so, we will not share your PII with third parties other than as specified in this Privacy Policy.

Disclosures to Third Parties Assisting In Our Operations.
  We may share your PII under confidentiality agreements and any legally required data processing agreements with other companies that work with, or on behalf of, Colgate or Kolibree to provide products and services, such as those who are performing research, marketing services, delivering goods or services, providing cloud hosting services, administering promotions, analyzing data and usage of the Products, processing payments, operating the Website, the Mobile App or Products, or providing support and maintenance services for the Products, as well as legal, regulatory, audit and other professional advisors.  These companies may use your PII to assist us in our operations or for our legitimate business interests.  However, these companies do not have any independent right to share this information.

Disclosures Under Special Circumstances. We may provide information about you, including PII, to respond to subpoenas, court orders, legal processes or governmental regulations or inquiries, or to establish or exercise our legal rights or defend against legal claims.  We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

Other Parties With Your Consent or At Your Direction. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such sharing.

Cookies

Please see the “Cookies” section of the Colgate Privacy Policy for information regarding the Website’s use of cookies.

Network Operators

Use of the Website or the Mobile App may involve use of the services of third-party telecommunications carriers and service providers (such as the services of the carrier that provides cellphone and Internet service to you). Such carriers and service providers are not contractors of Colgate or Kolibree, and any information that a carrier collects in connection with your use of the Services is not PII and is not subject to this Privacy Policy.  We are not responsible for the acts or omissions of telecommunications carriers or service providers.

Response to “Do Not Track” Signals

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates, although web browsers incorporate and activate this functionality in different ways, and it is not always clear whether users intend for these signals to be transmitted. There currently is disagreement, including among participants in the leading Internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals.  Colgate currently does not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.

Children's Privacy Protection

Under Age 13.   The Colgate Privacy Policy which describes how Colgate protects the privacy of children in accordance with the Children’s Online Privacy Protection Act and other applicable laws, also applies to the Website and the Mobile App.  The Website and the Mobile App do not knowingly solicit or collect personally identifiable information online from children under the age of 13 without prior verifiable parental consent.  Where required by applicable local law, the restrictions set forth in this Section applicable to children under age 13 may apply to children of a higher age.  If we learn that a child under the age of 13 (or such legally required higher age) has submitted personally identifiable information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personally identifiable information we have collected from children under 13 (or such legally required higher age), please contact us [https://www.colgatepalmolive.com/en-us/contact-us]

Nevertheless, children are allowed to use certain Services under parents’ supervision and with their verifiable consent in accordance with applicable legal requirements.  For example, the Mobile App includes features designed for children under age 13 to teach them how to brush properly, such as the Go Pirate! game.  The Go Pirate! game collects the following information from children under the age of 13:  (i) first name, (ii) age, (iii) handedness, and (iv) gender.  We encourage parents and legal guardians to monitor use of the Mobile App and the Product by those under 13 years of age.  We will not disclose such information of children with any third parties.

Under Age 18.  Minors under 18 (or such lower age, where required by applicable local law) years of age may have the PII that they have provided to us through the Website or Mobile App deleted by sending an email to https://www.colgatepalmolive.com/en-us/contact-us requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all our systems and back-up systems.

Privacy Settings/Opt Out/Changes/Access

If you would like your PII removed from our database, changed or updated, you can notify us through your personal account and you can contact us at to https://www.colgatepalmolive.com/en-us/contact-us.  If requested, we will promptly verify and delete your account and you will no longer receive emails from Colgate or Kolibree. Your removal from the mailing list or database will not remove records of past transactions or delete information stored in our data backups and archives where we are required to keep your data for legitimate business or legal requirements. Data on past transactions and data stored in backups and archives will be deleted in the normal course of our business.  You have the right to access or, if required by applicable laws, receive a copy of your PII held by us by making a written request by sending an email to the contact email address below.

Referrals/Links

The Website may contain links to other websites.  We are not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Website, and review the privacy statements of each third-party website. This Privacy Policy applies solely to information collected by the Website and Mobile App.

Website Visitors from Outside the United States

Colgate, Kolibree and their servers are located in the United States and Europe and are subject to the applicable laws of the United States (where data privacy laws are less stringent than in the European Union and some other jurisdictions) and the European Union, and, for Colgate, other jurisdictions.  If you choose to access or use the Services, you consent to the transfer, use and disclosure of information in accordance with this Privacy Policy and subject to such applicable laws.

Changes to this Privacy Policy

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. If we update the Privacy Policy, we will let you know about our changes we consider material by placing a note on the relevant web page you use to access the Services or you may receive an email with notification of the updated Policy. By accessing or using the Website or Mobile App after we have placed such a notice, you consent to the new practice(s) identified in the update. The most current version of the Privacy Policy will always be available on Colgate Connect at www.colgate.com/connect.  If you are a user of the Mobile App, the Privacy Policy will also be available in the app store from which you download the app. You can check the "effective date" posted at the top to see when the Privacy Policy was last updated.  Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.

Contact

If you have any questions about this Privacy Policy or about our handling of your information, please contact the Colgate Privacy Officer at https://www.colgatepalmolive.com/en-us/contact-us

TERMS OF USE

Effective Date: January 9, 2018,

This website, located at uniform resource locator www.colgate.com/connect (the "Website"), is provided by Colgate-Palmolive Company (“Colgate,” "we," "our," or "us") to the person accessing the Website ("you," or "your").

1. You Agree to These Terms by Using the Website

Your access to, and use of, the Website is subject to the general Terms and Conditions located at the Colgate-Palmolive website located (https://www.colgatepalmolive.com/en-us/legal-privacy-policy/terms-of-use) as well as the following terms of use and all applicable laws and regulations (collectively, the “Terms of Use.”  By accessing and using the Website, you accept, without limitation or qualification, these Terms of Use.  Colgate may, at any time and without notice, modify these Terms of Use by revising them on the Website.  Your continued use of the Website constitutes your acceptance of any such revisions.  You should therefore periodically visit this page to review the current Terms of Use.  You may not modify these Terms of Use except in a writing signed by Colgate.

If you do not agree and accept, without limitation or qualification, these Terms of Use, you must exit the site immediately.

2. Permitted Use of the Website

The information and materials on the Website are provided for general informational purposes. You may use the site solely for the purpose of learning about and/or purchasing Colgate Connect services or products, such as the Colgate Connect E1 Smart Toothbrush.  You may not use, reproduce or distribute the text, graphics, downloads, tools or any other content on the Website for any other purpose. 

3. User Submitted Content

The Website may, from time to time offer interactive features that allow users to submit content to the Website.  Colgate does not and cannot review all such content, and is not responsible for such content.

You acknowledge that by providing the ability to view and distribute your user-generated content on the Website, Colgate is merely acting as a passive conduit for such distribution and is not undertaking any obligation or liability related thereto. However, Colgate reserves the right to block or remove communications or materials that it determines to be unacceptable to Colgate in its sole discretion.

Harassment in any manner or form on the site, including via e-mail, chat, or by use of obscene or abusive language, is strictly forbidden. Impersonation of others, including a Colgate employee, host, or representative, as well as other members or visitors on the site is prohibited. You may not upload to, distribute, or otherwise publish through the site any content which is libelous, defamatory, obscene, threatening, invasive of privacy or publicity rights, abusive, illegal, or otherwise objectionable which may constitute or encourage a criminal offense, violate the rights of any party or which may otherwise give rise to liability or violate any law.

4. Notice; Electronic Communications

When you visit the site or send e-mails to Colgate, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on the site. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

5. Privacy 

Colgate Connect's Privacy Policy is incorporated and made part of these Terms of Use.  You hereby agree to such Privacy Policy.  Any personal data (for example, your name, address, telephone number or e-mail address) that you transmit to the Website by electronic mail or otherwise will be used by Colgate in accordance with the Privacy Policy. Any other communication or material you transmit to the Website, such as questions, comments, suggestions or the like, will be treated as non-confidential and non-proprietary.

6. Typographical Errors

In the event that a service or product is mistakenly listed at an incorrect price or with incorrect specifications, Colgate reserves the right to refuse or cancel any orders placed for product or service listed incorrectly, whether or not the order has been confirmed and whether or not you have been charged for such product or service. If your credit card has already been charged for the purchase and your order is cancelled, Colgate shall issue you a credit (to your credit card account or otherwise) in the amount of the incorrect price.

7. Third-Party Links

In an attempt to provide increased value to our visitors, Colgate may link to sites operated by third parties. However, even if the third party is affiliated with Colgate, Colgate has no control over these linked sites, all of which may have separate privacy and data collection practices, independent of Colgate.  These linked sites are only for your convenience and therefore you access them at your own risk.  Without limiting the foregoing, Colgate specifically disclaims any responsibility if such sites: infringe any third party's intellectual property rights; are inaccurate, incomplete or misleading; are not merchantable or fit for a particular purpose; do not provide adequate security; contain viruses or other items of a destructive nature; or are libelous or defamatory.

Colgate does not endorse the content, or any products or services available, on such sites.  Nonetheless, Colgate seeks to protect the integrity of its web site and the links placed upon it and therefore requests any feedback on not only its own site, but for sites it links to as well (including if a specific link does not work).

8. Copyright

Copyright © 2018, Colgate-Palmolive Company.  ALL RIGHTS RESERVED.

All content included on the Website, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of Colgate or its content suppliers and protected by United States and international copyright laws. The compilation of all content on the Website is the exclusive property of Colgate and protected by United States and international copyright laws. All software used on the Website is the property of Colgate or its software suppliers and protected by United States and international copyright laws.  You agree not to change or delete any proprietary notices from materials printed or downloaded from the site.

9. Export Control

Software and other materials downloaded or otherwise made available from the Website may be subject to United States Export Control. The United States Export Control laws prohibit the export of certain technical data and software to certain territories. No software from the Website may be downloaded or exported: into (or to a national or resident of) Cuba, Iraq, Libya, North Korea, Iran, Sudan, Syria, or any other country to which the United States has embargoed goods; or anyone on the United States Treasury Department's list of Specially Designated Nationals or the United States Commerce Department's Table of Deny Orders.

Colgate does not authorize the downloading or exportation of any software or technical data from the Website to any jurisdiction prohibited by the United States Export Control Laws.

10. Assignment

Colgate may assign its rights and duties under these Terms of Use to any party at any time without notice to you.

11. Questions and Feedback

We welcome your questions, comments, and concerns about the Website. Please send us any and all feedback pertaining to the Website to to https://www.colgatepalmolive.com/en-us/contact-us

By using our website you consent to all cookies in accordance with our privacy policy.