NEW PRIVACY STATEMENT
Thank you for visiting a website, mobile app or other online service (“Service”) that belongs to Us and is operated by Henkel Corporation or one of its subsidiary or affiliated companies ("Henkel", “Us”, “We”, “Our”). This Privacy Statement outlines the information Henkel may be collecting and how We use and protect that information.
Effective as of: November 14, 2017
This Privacy Statement applies to your use of any Service (e.g., website, mobile app or internet-connected product) that posts a link to, or otherwise provides notice of the applicability of, this Privacy Statement, regardless of how you access or use it. It does not apply to information We obtain in Our capacity as an employer except with respect to employment applications and inquiries received via the Service. This Privacy Statement applies to Our collection, use and disclosure of information about you through the Service and does not apply to Our activities off of the Service or third party websites accessible via hyperlinks found on a Henkel Service.
For certain aspects of the Service, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.
Henkel reserves the right to change this Privacy Statement prospectively effective upon the posting of the revised Privacy Statement and your use of the Service indicates your consent to the privacy statement posted at the time of use. However, We will not use your previously collected Henkel-Collected PI (defined below), to the extent it is not collected under the new privacy statement, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Statement is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
3. Information Collected
You can visit Our Service without telling Us who you are or revealing personal information about yourself, however, doing so may render certain Henkel service’s unavailable to you. You may, however, choose to provide (“Personal Information”) (defined as information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number).
The types of information that Henkel may collect about you include, but are not limited to:
- Contact information (such as name, address, city, state, province/territory, Postal/ZIP code, email address and telephone number).
- Product preferences.
- “Demographic information” such as age range, gender, date of birth, marital status, Postal/ZIP code, and household composition). Except to the extent required by applicable law, Demographic Information is “non-Personal Information” (i.e., data that is not Personal Information under this Privacy Statement).
- “Usage Information” such as IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Henkel with Personal Information, Henkel does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Henkel-Collected PI.
- Social Security Number (“SSN”)(in limited circumstances Henkel may collect SSN, for example if you win a sweepstakes or receive compensation that must be reported for government tax purposes).
- Photographs and videos (e.g., that are submitted by customers via websites such as part of contests or sweepstakes).
- Employment application information (such as SSN, Driver’s license, financial information, background screening, and gender or race [as permitted by law]).
If you choose to participate in the Service activities such as website registrations, contests, sweepstakes, questionnaires, surveys, consumer service contacts, product purchases, mobile applications, social media platforms, or through Our Career Center or employment inquiries, Henkel will collect the Personal Information that you provide (“Henkel-Collected PI”). We may enhance or merge the information that you provide to Us directly with information from other sources, including third parties for the purposes described below. To the extent any information is combined by or on behalf of Henkel with Henkel-Collected-PI, Henkel will treat the combined data as Henkel-Collected PI under this Privacy Statement.
4. Information Use
We collect, maintain and use your Henkel-Collected-PI, other Personal Information, and other information, for purposes not inconsistent with this Privacy Statement or any written statements We make at the time of collection, such as for:
- establishing and verifying the identity and eligibility of users;
- opening, maintaining, administering and servicing users profiles, accounts or memberships;
- processing, servicing or enforcing transactions and sending related communications;
- providing products, services and support to users;
- conducting sweepstakes, surveys and contests, and providing the results thereof;
- operating and improving the Service, including tailoring it to users' preferences;
- providing users with product or service updates;
- sending promotional notices, offers or other targeted marketing, and other information;
- responding to your questions, inquiries, comments and instructions;
- maintaining the security and integrity of Our systems;
- understanding consumer preferences across multiple brands;
- maintaining customer relationships;
- evaluating product performance and safety;
- complying with policies, procedures and legal requirements; and
- improving or products and services and Our other business purposes.
Information that you provide when applying for a job or an internship via Our Careers Center is used to provide you with information about employment opportunities, to administer the application process and consider you for employment. Where applicable, in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, We may ask you to provide Us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide Us with such information, We may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
5. Information You Disclose Publicly or to Others
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Henkel relies on you to only send to people that have given you permission to do so. The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Henkel for any other marketing purpose unless Henkel obtains consent from that person. Your full name, contact information and message may be included in the communication. For residents of Canada, you may only provide us with the contact information of friends with whom you have had direct voluntary two way communications, and with whom it is reasonable to conclude you have a personal relationship considering shared interests, experiences, opinions and other relevant factors. You may only provide email addresses of family members to whom you are related by marriage, a common-law partnership, or parent-child relationship, and with whom you have had direct voluntary two way communications.
6. Technology Logging, Cookies, and Related Techniques
When you interact with Our Service, your browser or device may communicate with the technology that We use as part of Our Service. For example, as you use Our Service, your browser communicates with Our technology, which in turn keeps records of your interactivity and requests for services and content to assist Us in managing and improving the utility of Our Service, and to conduct research and analysis on its use. The types of such Usage Information may include your Internet Protocol (IP) address, browser type, URL, requests made, pages visited, activities conducted on the page, day and time of visit and related technical usage information.
Cookies and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior, to authenticate you to the Service, to analyze how the Service is used, to link information about how you use the Service with your account, and to help tailor Our services. We use these technical means and so do Our Affiliates, business partners, and Service Providers. To help Us measure Service activity and provide a better user experience, We may allow Our Service Providers or business partners to compile information such as that identified above from Tracking Technologies. We may also allow Our third party advertising and personalization partners to collect and use this information to develop personalized content and appropriate advertising (including for companies not affiliated with Us) based on your visits over time on Henkel and non-Henkel websites, apps and other online services. You may see these advertisements on other websites, apps and online services. This information may also be used to evaluate Our and third party online advertising campaigns or to tailor promotions and other marketing messages to you on Our Service and other websites apps and online services.
A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all of these types of cookies with your devices. Other types of Tracking Technologies may include web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, and in-app tracking methods. See Section 11 regarding certain choices regarding these activities.
7. Data Sharing and Storage
Henkel may disclose your information to third parties to the extent not inconsistent with this Privacy Statement or other written statements made by Us at the time of collection, and not prohibited by applicable law, including without limitation as follows:
- Henkel’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including, without limitation, Henkel-Collected-PI and other Personal Information, Demographic Information, and Usage Information, in connection with their work on Henkel’s behalf, provided however, Henkel does not authorize its Service Providers to use Henkel-Collected-PI to send you direct marketing messages other than related to Henkel and Henkel Affiliates absent your consent. For more information on choices Service Providers may offer you see Section 11.
- We reserve the right to release your Henkel-Collected-PI and other Personal Information if required to do so by law, search warrant, subpoena, court order or upon request of government authorities.
- We may provide your Henkel-Collected-PI and other Personal Information, and other information, to third parties in connection with the reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Our business, assets, or stock, including any such activities associated with a bankruptcy or similar proceeding.
- Henkel may share your Personal Information with its affiliated companies and subsidiaries (“Affiliates”), and other third parties, some of which may be located outside of the United States, for marketing and other business activities, subject to certain rights of residents of California and Connecticut [see Section 12].
Your Personal Information may be stored for a reasonable amount of time in Henkel databases, some of which are located outside of the United States and Canada, and will be automatically transferred to these databases for storage and maintenance. The Service is based in the U.S., intended for residents of the U.S. and Canada and for persons outside Canada, the information Henkel and its Service Providers collect via the Service is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence and provide a lower level of consumer protection, and information transferred to the U.S. may be accessed by U.S. governments and law enforcement in accordance with U.S. laws. Your use of the Service, or provision of any information via the Service, therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Statement.
8. Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics
The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technologies to independently collect information about you and may solicit Personal Information from you. Henkel is not responsible for the privacy practices or the content of the Third-Party Services. Please note that the privacy statements applicable to such Third-Party Services may differ significantly from the Henkel Privacy Statement, so We advise you to read them carefully before using those services. You agree that Henkel shall not be held liable for any actions by or content of such Third-Party Services.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Henkel’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Henkel or other Henkel Affiliates in a tweet or status update), you agree that your post may be used on or in connection with the Service or otherwise by Henkel or other Henkel Affiliates. Also, both Henkel and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Henkel may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a Third-Party Service after you have left the Service (i.e., “retargeting”). As an example, the Service may employ a “DoubleClick id-Cookie,” which may assign a pseudonymized identifier to, among other things, track DoubleClick advertising. DoubleClick is a service provided by Google. For information on your ability to opt-out of Interest-based Advertising see section 11 below.
Except to the extent We combine information We receive from Service Providers, Third-Party Services, or other third parties with Henkel-Collected PI, in which case Henkel will treat the combined information as Henkel-Collected PI under this Privacy Statement, data obtained by Henkel from a third party, even in association with the Service, is not subject to Henkel’s limitations regarding Henkel-Collected PI under this Privacy Statement, however such data remains subject to any restrictions imposed on Henkel by the third party, if any. Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with Henkel, the types of information shared, and your choices on what is visible to others on Third-Party Services.
9. Security and Monitoring
Henkel will take reasonable precautions to protect your Personal Information (excluding public UGC) from loss, misuse or alteration. Personal Information may be accessed by persons within Our organization, or Our third party service providers, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception and that the internet and online digital storage are not completely secure and We do not guarantee the security of your information collected through the Service.
The Service is intended for a general audience and not directed to children less than 13 years of age. Henkel does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If We obtain knowledge that We have collected Children’s Personal Information in a manner not permitted by COPPA or other applicable law, We will remove such data to the extent required by COPPA or such other applicable law.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Henkel here detailing where the content or information is posted and attesting that you posted it. Henkel will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Henkel does not control.
11. Your Choices Regarding Your Personal Information
A. Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Henkel currently does not alter Henkel’s practices when Henkel receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but We are not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on Our Site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Henkel is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
B. Analytics and Advertising Tracking Technologies
You may choose whether to receive some Interest-based Advertising by submitting opt-outs to industry programs. Some of the advertisers and Service Providers that perform advertising-related services for Us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Some companies also provide a specific opportunity to opt-out. For information on the Interest-based Advertising choices offered by DoubleClick, see here. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use of a different device or web browsers or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective. Henkel supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Henkel directly engages to serve you Interest-based Advertising will do so as well, though Henkel cannot guaranty their compliance. Henkel is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Mobile Apps
With respect to Henkel’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or Our networks) may persist. See also the prior section regarding the DAA’s mobile Interest-based Advertising choices.
You can opt out of receiving certain promotional communications (emails or text messaging) from Henkel at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from Henkel to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Henkel may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Our ongoing business relations.
E. Careers Center
If you have created a resume using Our Careers Center you may access, review, correct, update, change or delete your account profile information or resume at any time. Simply log into your account, go to your profile or resume, and make the necessary changes. You may delete your resume from Our online database at any time by accessing your account; provided, however, that We reserve the right to maintain a copy (a) as required by applicable law; and (b) for so long as reasonably necessary for record keeping purposes except to the extent prohibited by applicable law.
12. Your California and Connecticut Privacy Rights
A. California Rights: Henkel provides California residents with the option to opt-in or opt-out to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than Henkel Affiliates, for such third parties own direct marketing purposes. California residents may exercise that opt-out, and/or request information about Henkel’s compliance with the Shine the Light law, and obtain disclosure of third parties Henkel has shared information in accordance with the law for their direct marketing purposes absent your choice and the categories of information shared, by contacting Henkel here or by sending a letter to Henkel at:
Attention: Henkel Privacy Inquiries
One Henkel Way
Rocky Hill, CT 06067
Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Henkel is only required to respond to one request per customer each year, and Henkel is not required to respond to requests made by means other than through the provided e-mail address or mail address.
B. Connecticut Rights:Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is Our policy to protect the confidentiality of Social Security numbers in Our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
13. Mobile Applications Privacy Statement
Henkel has developed certain mobile applications that you may download to your mobile device. When you download a mobile application there may be an opportunity for you to provide Us with or for Us to obtain information about you such as contact information, product preferences, photographs, or other information. In addition, We may obtain information about the mobile device, such as device ID and operating system, and app usage. Information obtained through a mobile application will be used in accordance with this Privacy Statement and may be subject to additional terms posted within the mobile application.
14. Accessing and Changing Information
Henkel may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Henkel-Collected PI, and potentially certain other information about you (e.g., profile and account information). You may also request access to your Personal Information and to request a correction to it if you believe it is inaccurate using the contact information provided below. We may require you to verify your identity before allowing you to access your information. Henkel will make good faith efforts to make requested changes in Henkel’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Henkel’s databases Further, We reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
Please send Us your questions or comments regarding Our privacy practices by emailing Us at PrivacyNA@henkel.com, or sending Us a letter addressed to:
Henkel Privacy Inquiries
One Henkel Way
Rocky Hill, CT 06067