COLGATE CONNECT PRIVACY POLICY – Colgate Connect UK

COLGATE CONNECT PRIVACY POLICY

Colgate-Palmolive Company (“Colgate”) wants you to be familiar with how we collect, use, and disclose information in connection with the Colgate Connect E1 Smart Toothbrush.  This Privacy Policy describes our practices in connection with information that we collect through the mobile application (the “App”) that you may choose to pair with the toothbrush and the Colgate Connect website (the “Site”) from which you are accessing this Privacy Policy (collectively, the “Services”).

PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF INFORMATION FROM U.S. CHILDREN UNDER AGE 13 AND CHILDREN OUTSIDE THE U.S. UNDER AGE 16. 

RELATIONSHIP WITH KOLIBREE

The toothbrush and App are powered by Kolibree SAS and its subsidiaries (“Kolibree”).  Colgate is a licensee of Kolibree and has entered into a development agreement with Kolibree.  Under this arrangement, Colgate and Kolibree each own any data generated by use of the toothbrush and App.  Kolibree has the same rights to use and disclose the information collected through the toothbrush and the App as Colgate, as described in this Privacy Policy.  The terms “we,” “our,” or “us,” when used in this Privacy Policy, refer collectively to Colgate and Kolibree.  

Personal Information

Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as:  

  • First and last name
  • Postal address
  • Telephone number
  • Email address
  • Profile picture
  • Social media account ID  

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including: 

  • Through the App 

We collect Personal Information through the App, such as when you provide your email address or a profile photo in connection with account creation.

  • Through the Site

We collect Personal Information through the Site, such as when you purchase products, contact us via chat or email, or subscribe to our newsletter.

  • From Other Source

If you connect your social media account to your Services account, you will share your email address from your social media account with us.

 

We need to collect Personal Information in order to provide the requested features of the Services to you.  If you do not provide the information requested, we may not be able to provide all of the Services’ features to you.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

 

Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes, including:

  • To provide the functionality of the Services and fulfill your requests.
  • To provide the Services’ functionality to you, such as, if you use the App, providing you with a weekly review of your brushing activity and providing you with related customer service.
  • To fulfill your orders for Colgate Connect products and provide you with related customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.

 

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • To provide you with our newsletter and other marketing materials.
  • To send you marketing related emails and push notifications, with information about our services, new products, and other news about our company.

 

We will engage in this activity with your consent or where we have a legitimate interest. 

  • To analyze Personal Information for business reporting and to provide personalized services.
  • To better understand you (including, if you use the App, your brushing habits), so that we can personalize our interactions with you and provide you with content, information, and/or offers tailored to your interests.
  • To analyze your use of the Services so that we can improve them.

 

We will provide personalized services either with your consent or because we have a legitimate interest.

  • To aggregate and/or anonymize Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
  • To accomplish our business purposes.
  • For data analysis, such as to improve the efficiency of the Services.
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements.
  • For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft.
  • For research and developing new products and services.
  • For enhancing, improving, or modifying our current products and services.
  • For identifying usage trends, such as understanding which parts of the Services are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that we can adapt them to our users’ needs and interests.
  • For operating and expanding our business activities, including understanding which parts of the Services are most used so we can focus our energies on meeting our users’ interests.

 

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

 

Disclosure of Personal Information  

We disclose Personal Information:

  • To our affiliates, for the purposes described in this Privacy Policy.
  • You can consult the list and locations of our affiliates here.
  • Colgate-Palmolive Company is the entity responsible for the management of jointly-used Personal Information.
  • To our third-party service providers, to facilitate services they provide to us.
  • These can include providers of services such as research and development, marketing, cloud and website hosting, data analysis, information technology, and customer service.
  • When you elect to disclose your Personal Information.
  • You or we may share your Personal Information when you consent to or request such sharing, or when, in the case of a child, the child’s parent or legal guardian consents to such sharing. For example, you may ask us to share your Personal Information, along with information about your brushing activity, with your dentist or insurance company.    
  • If you choose to connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing, and you understand that the used of shared information will be governed by the social media provider’s privacy policy.
  • You may choose to share your Personal Information when you post a product review or a comment in response to a blog post on the Site. Please note that any information you post or disclose by doing so will become public information.

 

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
  • This can include laws outside your country of residence.
  • To cooperate public and government authorities.
  • To respond to a request or to provide information we believe is important.
  • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
  • For example, to respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons.
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
  • In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

 

OTHER Information

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual.  If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including: 

  • Information you provide
  • We ask you to provide information that does not reveal your specific identity, such as your first name, age, gender, and whether you are left- or right-handed.
  • Through your device
  • Certain information is collected automatically through your device or browser, such as a device ID, your screen resolution, operating system, device manufacturer and model, language, default country setting, and Internet browser type and version. We use this information to ensure that the Services function properly.  We use the device ID to send you push notifications, subject to your consent (or parental consent) where required by applicable law.
  • Through your use of the Services
  • When you download and use the App, we will collect information about your use of the App, such as features used and the dates and times of your interactions with the App. We also collect information about your brushing, such time spent brushing, frequency of brushing, areas of the mouth brushed, and position of the toothbrush.  We use this information to understand how the Service is used, including which App features and interactions help improve brushing technique.
  • Using cookies
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Site in order to continually improve its design and functionality, understand how it is used, and assist us with resolving questions about it.  We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site.
  • Using tracking technologies
  • We may use tracking technologies to recognize you as you use the Services, so that we can understand how the Services are used and optimize user engagement. We may also use pixel tags (also known as web beacons and clear GIFs) in the emails we send, to track recipients’ actions and response rates. 
  • We use Google Analytics, which uses tracking technologies to collect and analyze information about use of the Services and to report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/.
  • IP Address
  • We collect your IP address, which is automatically assigned to your device by your Internet service provider. An IP address may be identified and logged when you access the app, along with the time of the visit.  We use IP addresses for purposes such as calculating usage levels, diagnosing problems, and administering the app. 

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization.  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 Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt-out from: 

  • Receiving electronic communications from us:  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the instructions contained in each such email.
  • Receiving push notifications from us:  You may stop the receipt of push notifications through your device settings.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change, or delete your Personal Information 

You may update or correct certain of your Personal Information through your Services account settings.  You may also contact us at teamconnect@colgate.com if you would like to request to review, correct, update, suppress, restrict, or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information 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 respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information.  For your protection, we may only implement requests with respect to the Personal Information 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 information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. 

RETENTION PERIOD

We retain Personal Information 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: 

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep transaction records for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

 

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information 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 Information you disclose to other organizations through or in connection with the Services.

OUR COLLECTION OF PERSONAL INFORMATION FROM CHILDREN

The Site is not directed to children, and we do not knowingly collect Personal Information 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 Information from the child.  We and our service providers also collect the information described above, under “Other Information,” 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 Information as described above, under “Use of Personal Information” and “Disclosure of Personal Information.”

If you would like to review the Personal Information we have collected from your child, or if you would like to ask us to make no further use of, or delete, the Personal Information 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 Information 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 information 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 Information.

Additional Information Regarding the 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 and binding corporate rules, to protect your Personal Information.  You may obtain a copy of these measures by contacting .

SENSITIVE INFORMATION

we ask that you not send us, and you not disclose, any sensitive Personal Information (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.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy. 

THIRD PARTY PAYMENT SERVICE

We may use a third-party payment service to process payments made through the Services.  If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

CONTACTING US

Colgate-Palmolive Company, located at 300 Park Avenue, New York, New York 10022, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at , , or:

 

Colgate-Palmolive Company

300 Park Avenue

New York, NY 10022

 

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

ADDITIONAL INFORMATION FOR THE EEA

You also may:

Your Personal Data and Facebook 


As part of our Services, we use certain Facebook products for analytics and/or advertising.  Those products may share your Personal Data with Facebook, including Facebook Ireland Limited and Facebook, Inc.  For more information regarding Facebook’s use of this data, please visit the Facebook Custom Audiences Terms and the Facebook Business Tool Terms. Facebook Ireland Limited is a Joint Controller of this Personal Data.  For information regarding the Joint Controller relationship, and Facebook Ireland Limited’s responsibilities, please visit the Facebook Controller Addendum.  For more information about how Facebook processes Personal Data and how you may exercise your rights, please visit Facebook Ireland’s Data Policy.  Facebook Ireland Limited is transferring Personal Data from the EEA to Facebook, Inc. in the United States for storage and further processing.  For information about this transfer, please visit the Facebook EU Data Transfer Addendum

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