PRIVACY POLICY

1. Name and address of the Controller and information about our Data Protection Officer
The data controller (or equivalent) [DLAP1] within the meaning of the General Data Protection Regulation (GDPR)the Personal Data (Privacy) Ordinance (Cap. 486) and other national data protection laws of the member states as well as other applicable data protection laws and regulations is:
KPSS Hong Kong Limited
Unit A, 30/F, Tower A, Billion Centre, No.1 Wang Kwong Road,Kowloon Bay,Kowloon, Hong Kong
 It will be referred to as “we”, “us” or “Controller” in this Privacy Policy. In this Privacy Policy, “personal data” refers to any information through which you can be directly or indirectly identified as an individual. “Kao Group” refers to our parent entity, Kao Corporation in Japan, and each of its affiliates and/or subsidiaries (each affiliate or subsidiary including us referred to as "Kao Company"). 
We may update this Privacy Policy from time to time. Where we are required to do so by applicable law, we will seek your consent to such changes.

2. Categories of Personal Data and Processing Purposes - What personal data do we process about you and why?
The types of personal data we process about you and what we process it for depend on the relationship we have with you and the products or services that we provide to you. We may also process your personal data for any purposes directly related to the below.
Your IP address will be used to enable your access to our Website. The metadata will be used to improve the quality and services of our Website and services by analyzing the usage behavior of our users.
 
2.1 Metadata
You may use this Website without providing any personal data about you directly. In this case, we will collect only the following metadata that result from your usage of the Website: browser type and version, operating system and interface, website from which you are visiting us (referrer URL), webpage(s) you are visiting on our Website, date and time of accessing our Website and internet protocol (IP) address. Your IP address will be used to enable your access to our Website. The other metadata will be used to improve the quality and services of our Website and services by analyzing the usage behavior of our users.
2.2 Contact form
On our website, we offer you the opportunity to contact us via a contact form. To be able to process your request, we need to collect the following information from you, which can also include personal data: your email address and message contents. The provision of further personal data (for example your name) is possible, but not mandatory. The personal data that you provide us in the context of this contact form will be used to answer your inquiry / contact request and for the associated technical administration.  
2.3 Newsletter
If you request to receive our newsletter, we process the following information from you, which can also include personal data: your email address. The provision of further personal data (being your name, salutation and contact information) is possible, but not mandatory. We process such personal data for purposes of providing the newsletter about products, services, news, offers, promotions and events which we think may be of interest to you to the extent permitted by applicable law and analyzing your interests for marketing purposes. We may not do so unless we have received your consent and you can withdraw your consent without charge at any time by contacting us (see Section 8 below). In particular, your salutation and your name are requested in order to provide you with a personalized experience.
Under certain circumstances, the newsletter will not be sent by the Controller, but by another Kao Company (in particular Kao Germany GmbH). In this case, this Kao Company will receive your email address and if applicable, name, salutation and contact information from us to facilitate them in sending you the newsletter about products, services, news, offers, promotions and events which we think may be of interest to you, which may be for our commercial gain. We may not share your personal data with this Kao Company without your consent, and you can withdraw your consent without charge at any time by contacting us (see Section 8 below).
2.4 Become a stockist
On our website, we offer you the opportunity to become a stockist. For this we need the following personal data from you: your email address. The provision of further personal data (for example your name) is possible, but not mandatory. The personal data that you provide us in this context will be used to contact you regarding your interest as a stockist. If you want to become a stockist, we may request and subsequently process further data from you (e.g. being your name, salutation and contact information) that is necessary for our business relationship.
2.5 Salon finder
On our website you have the opportunity to find the nearest salons to your location that offers our products. You have the option of having your location determined by geolocation based on your IP address or by manually entering a postal code or address. We process such information for the purposes of facilitating your search for salons near you on our Website.

3. Processing Basis and Consequences - What is the legal justification for processing your personal data and what happens if you choose not to provide it?
The provision of your personal data is not required by a statutory or contractual obligation. The provision of your personal data is necessary to enter into a contract with us or to receive our services/products as requested by you. The provision of your personal data is voluntary for you. Not providing your personal data may result in disadvantages for you. If you do not provide us personal data that is required for the purposes described in this Privacy Policy, we may not be able to administer and manage our relationship with you (such as communicate with you or perform our contract with you, if any), which in some cases may mean we are unable to continue with your engagement with us if applicable, or we may be prevented from complying with our legal obligations. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.

4. Categories of Recipients and International Transfers - Who do we transfer your personal data to and where are they located?
We may transfer your personal data to third parties for the processing purposes described above as follows:

• Within the Kao Group: Any Kao Company may receive your personal data as necessary for the processing purposes described above. Depending on the categories of personal data and the purposes for which the personal data has been collected, different internal departments within the Kao Company may receive your personal data. Moreover, other departments within the Kao Company may have access to certain personal data about you on a need to know basis, such as the legal department, the finance department or internal auditing.
• With data processors: Certain third parties, whether affiliated or unaffiliated, may receive your personal data to process such data under appropriate instructions ("Processors") as necessary for the processing purposes described above, such as Website service providers, order fulfilment providers, customer care providers, marketing service providers, IT support service providers, and other service providers who support us in maintaining our relationship with you. The Processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data, and to process the personal data only as instructed.
• Other recipients: We may transfer - in compliance with applicable data protection law - personal data to law enforcement agencies, governmental authorities, judicial authorities, legal counsel, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties involved in the merger or acquisition. Except as otherwise stated in this Privacy Policy, we will not disclose your personal data to third parties for advertising or marketing purposes or for any other purposes without permission. Any access to your personal data is restricted to those individuals that have a need-to-know in order to fulfill their job responsibilities.

We will obtain your consent to the disclosure of your personal data where we are required to do so under applicable law.
International transfers: The personal data that we collect or receive about you may be transferred to and processed by recipients that are located inside or outside the jurisdiction where it was collected. We will take all necessary measures to ensure that transfers out of the applicable jurisdictions are adequately protected as required by applicable data protection law.
 
5. Retention Period - How long do we keep your personal data?
We take appropriate technical, physical and organizational measures to ensure that your personal data is secured against unauthorized or accidental access, processing, erasure, loss or use.
Your personal data will be retained as long as necessary to provide you with the services and/ or products requested by you. Once your relationship with us has ended or the purpose for which the data is processed is otherwise satisfied, we will remove your personal data from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information to comply with legal or regulatory obligations to which the Kao Company is subject, e.g. taxation purposes – see below.
In some cases, we may be required by applicable law to retain certain of your personal data for a period of time after the relevant taxation year. We may also retain your personal data after the termination of the contractual relationship if your personal data are necessary to comply with other applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need to know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship.
6. Your Rights - What rights do you have and how can you assert your rights? Subject to, and to the extent permitted by applicable data protection law, you may have various rights in relation to the personal data we collected and/or hold about you. If you are a resident in Hong Kong, this includes the right to: (i) request access to your personal data; and (ii) request rectification of your personal data.
Please note that these aforementioned rights might be limited under the applicable local data protection law.

7. Cookies and other tracking technologies
This Website uses cookies and other tracking technologies. For further information, please visit our Cookie Policy.
This Website may contain links to and from third party websites from time to time. These websites have their own privacy policies which would apply, which you should read carefully before you submit any personal data on such websites. We are not responsible for the content of these websites or their privacy policies, nor do we have any control over personal data that is submitted to these websites.
8. Questions and Contact Information
If you have any questions about this Privacy Policy or if you want to exercise your rights as stated above in Section 6, please contact us at dataprivacy.emea@kao.com or info@kpss-hair.com.hk if you are a resident in Hong Kong.