Last Updated: March 2022

We are committed to your privacy. We want you to be familiar and comfortable with what we do with your personal information. Our goal is to use your information to give you the most gracious customer experience, whether you are creating an account, purchasing our products and services, working with our customer support specialists, visiting our websites or other ways you are interacting with our company.

(1) Scope:

Listed below are the highlights of the Kohler Co. privacy policy. This policy applies to Kohler Co brands and customers and to Kohler.com visitors unless a separate privacy notice is prominently displayed. Our full privacy policy with all the details can be found here[Hyperlink ].

(2) Data Access & Collection

We collect personal data – such as your name, email address, location, and other information – directly from you

  • When you buy our products
  • When you contact Kohler Co.
  • When you use our website
(3) Uses

We use your information

  • To provide you with seamless customer support
  • To improve our product and service offerings and ensure we are meeting your customer expectations
  • To help customize your online experience with more products and offers relevant to you
(4) Your Choices
  • You are in control of your personal information in your account, and you can exercise your rights and change your preferences anytime.
  • We only market other Kohler Co products and services to you with your consent, based on your marketing preferences [Make this a hyperlink to unsubscribe and to provide the privacy email box].
(5) Regional Disclosures

Kohler Co. does business through its subsidiaries/affiliates worldwide. We comply with the different privacy laws and regulations in the jurisdiction we operate.

  • European Economic Area [All as hyperlink to a separate tab under the full policy ]
  • California Residents
  • Nevada Residents
  • Cross-Border Transfer
(6) FAQ

Commonly asked questions about how we collect, store and use your data.

  • Does Kohler Co. sell your personal data? No [Add hyperlink to the “No” for explanation”]
  • Does Kohler Co. share your data with service providers? Yes
  • Does Kohler Co. use your data for promotions? Yes
  • Etc.
(7) Controller and Privacy Contacts

You may access information we maintain about you by contacting the Global Data Privacy program at KohlerGlobalDataPrivacy@kohler.com

The privacy laws in some countries consider a Controller to be the legal entity (or natural person) who defines the purposes for which the processing of personal information takes place and how that information is processed. Where Kohler Co. or affiliate/subsidiary it controls is required to appoint a legal representative, the following controller have been appointed.

[Enter name and address here ]

Jurisdictions to be called out: California, Nevada, GDPR, and China addendum

WHO WE ARE

Kohler Co. and its affiliates (“Kohler”) are committed to your privacy. We want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect online and offline:




INFORMATION COLLECTED

TYPES OF INFORMATION WE COLLECT

We collect two basic types of information: Personal Information and Other Information (anonymous information!!) as defined in this policy. If we are required to treat Other Information as Personal Information under applicable law, then we will collect, use and disclose it for the purposes for which we collect, use and disclose Personal Information as detailed in this Policy.

We Collect:

  • Personal contact information such as name, address, telephone number and email address;
  • Business contact information such as business address, telephone number and email address;
  • Information necessary to provide services or products to you;
  • Comments and opinions you provide when you contact us directly by email, telephone or mail;
  • Payment and transaction information for billing purposes;
  • Browser and device information;
  • App usage data;
  • Information collected through cookies, pixel tags and other technologies. For more information regarding our use of cookies, click here https://www.kohlercompany.com/cookie-policy/.
  • Demographic information and other information provided by you that does not reveal your specific identity;
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity.

 

HOW WE COLLECT YOUR INFORMATION

We and our service providers may collect Personal Information online in a variety of ways in connection with our services or products, including:

Online
  • Through our websites (“Websites”);
  • Through the software applications made available by us for use on or through computers and mobile devices (“Apps”);
  • Through social media properties (“Our Social Media”);
  • Through HTML-formatted email messages that we send to you that link to this Privacy Policy (“Emails”);
  • Through extranet sites made available to our clients and third parties (“Extranet Sites”);
  • Through services we provide to our corporate and institutional clients (“services”); and
  • Through our registration process for newsletters, seminars, webinars and events.
Offline
  • When you participate in a contractual arrangement for services or products;
  • When you provide information in conjunction with our services or products; or
  • When you interact with us at an event.
Other Sources
  • Publicly available databases;
  • Joint marketing partners and event sponsors, when they share the information with us;
  • Other entities or franchisees to which we provide products and services;
  • Referral sources; and
  • Social media platforms.

 

USE OF YOUR INFORMATION BY KOHLER

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

  • Providing you with our marketing materials and facilitating social sharing
    • To send you our offers, newsletters, publications, updates, and mailings related to our products or services that we think may be of interest to you.
    • To fulfill your event or accommodation registration requests and provide goods and services and resort services.
    • To send you information about our products and services and other news about products or services which we have reason to believe will be of interest to you.

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

  • Providing the functionality of our Products and Services and fulfilling your requests
    • To provide our products and services functionality to you, such as arranging access to your registered account, and providing you with related goods and services.
    • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions, suggestions, compliments or complaints, or when you request other information about our products or services).
    • To send administrative information to you, such as information regarding our products and services, guarantees and warranties and 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.

  • Accomplishing our business purposes
    • For data analysis, for example, to improve the efficiency of our goods and services and quality of our products.
    • 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, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
    • To meet our legal and regulatory obligations.
    • For enhancing, improving, or modifying our current products and services.
    • For identifying usage trends, for example, understanding which parts of our products and services are of most interest to customers.
    • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our customers.
    • For operating and expanding our business activities, for example, understanding which parts of our services or products are of most interest to our customers so we can focus our energies on meeting our customers’ 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.


 

SHARING YOUR INFORMATION

We disclose Personal Information:

  • To our affiliates for the purposes described in this Privacy Policy
    • You can consult the list and location of our affiliates listed at the bottom of this page. Subject to local requirements, this information may be used to provide products and related products and services offered by our other legal entities and for all the purposes outlined in this Privacy Policy.
    • Kohler Co. is the party responsible for the management of the 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 website hosting, services-related consulting and monitoring, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
  • By using our Services, you may elect to disclose Personal Information
    • On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media), or through which you are able to send messages through the systems. Please note that any information you post or disclose through these systems will become public and may be available to other users and the general public.

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 including laws outside your country of residence.
  • To cooperate with public and government authorities, including authorities outside your country of residence.
  • To cooperate with law enforcement.
  • For other legal reason such as 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, merger or business transaction.

 

RETENTION OF YOUR INFORMATION

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 our products and services to you (for example, for as long as you have an account with us or keep using our products and services);
  • The length of time we have an ongoing relationship with you as our client and provide you with products and services;
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications 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).

 



DATA SECURITY & CONTROLS

DATA SECURITY AND INTEGRITY

We have implemented internal policies and technical measures to protect Personal Information from loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:

  • The use of pseudonymization and encryption of personal data where appropriate;
  • Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • Procedures and controls to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  • Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing; and
  • Procedures to ensure that data is not accessed, except by individuals in the proper performance of their duties.

 

YOUR CONTROLS AND CHOICES

You have choices regarding marketing-related communications. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at KohlerGlobalDataPrivacy@kohler.com. 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.


 



ADDITIONAL INFORMATION

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.

This includes any third party operating any website or service to which our websites may link. The inclusion of a link 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, RIM 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 Apps or our Social Media.


 

USE OF OUR SERVICES BY MINORS

The goods and services we provide are not directed to individuals under the age of [sixteen (16)], and we do not knowingly collect Personal Information from individuals under [16].


 

CROSS BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have affiliates, outlets and facilities or in which we engage service providers. By using our 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.

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 Information. You may obtain more information by reaching out to us at KohlerGlobalDataPrivacy@kohler.com.


 

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. Your use of our online services following these changes means that you accept the revised Privacy Policy.


 


CONTACTING US

Kohler Co. 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 KohlerGlobalDataPrivacy@kohler.com. The list of relevant data comptrollers can be found here.




CALIFORNIA SUPPLEMENTAL PRIVACY NOTICE


This California Privacy Policy is intended to comply with the California Consumer Privacy Act (CCPA), California Online Privacy Protection Act (CalOPPA), California Notice Data Security Act and other applicable privacy laws. Consumers with disabilities may access this policy in an alternative format by sending an email to: KohlerGlobalDataPrivacy@kohler.com.

For purposes of this California Privacy Policy, “Personal Information” means anything that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular California consumer or household.

Kohler Co. does not sell personal information.

As a California resident, you have the following rights regarding the Personal Information we collect about you:

Right to Notice

You have the right to receive notice of the categories of Personal Information we collect prior to or at the time we collect your Personal Information. The Personal Information we collect about California residents is described above in the section titled WHAT INFORMATION WE COLLECT. The business or commercial purposes for the collection of your Personal Information are described above in the section titled HOW WE USE PERSONAL INFORMATION .

Right to Know

You have the right to know about the Personal Information we collected and disclosed about you and your household during the prior 12 months. You can obtain the Personal Information we collected and/or disclosed about you by calling us at our toll-free telephone number: 1-800-923-1138 or emailing us at: KohlerGlobalDataPrivacy@kohler.com. To ensure that the request is coming from you and to protect the security of your Personal Information, we may require you to provide us with certain information to verify your identity such as your email address, your telephone number, a description of the product or service you purchased or inquired about, the dollar amount of your last purchase and/or a signed declaration under penalty of perjury from you that you are the consumer whose Personal Information is subject to the request. You may use an authorized agent to exercise your right to know if the authorized agent has your power of attorney act on your behalf or the authorized agent has your written authorization permitting the authorized agent to request access to your Personal Information.

Right to Delete

You have the right to request us to delete the Personal Information that we have collected or maintained about you and your household. You can request us to delete your Personal Information by calling us at our toll-free telephone number: 1 800 923-1138 or emailing us at: KohlerGlobalDataPrivacy@kohler.com. To ensure that the request is coming from you and to protect the security of your Personal Information, we may require you to provide us with certain information to verify your identity such as your email address, your telephone number, a description of the product or service you purchased or inquired about, the dollar amount of your last purchase and/or a signed declaration under penalty of perjury from you that you are the consumer whose Personal Information is subject to the request. You may use an authorized agent to exercise your right to delete if the authorized agent has your power of attorney act on your behalf or the authorized agent has your written authorization permitting the authorized agent to request deletion of your Personal Information.

Right to Nondiscrimination

You have the right to receive our products and services on equal terms regardless of whether or not you exercise your rights under the CCPA.

Right to Request Information About Disclosures

You may request information about any disclosures of categories of Personal Information we make to our affiliates or third parties for their direct marketing purposes. We will provide a list of the categories of Personal Information disclosed to third parties or our affiliates for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties or affiliates. Your request may be made no more than once per calendar year. You may submit your request by emailing us at: KohlerGlobalDataPrivacy@kohler.com. We do not respond to “Do Not Track” requests.

If you have questions or concerns regarding this Privacy Policy, please email us at: KohlerGlobalDataPrivacy@kohler.com.


 

NEVADA SUPPLEMENTAL PRIVACY NOTICE


You have the right to direct us not to sell certain personally identifiable information that we collect about you on our Websites or other online services by emailing us at KohlerGlobalDataPrivacy@kohler.com. This information includes: your first name or first initial and last name in combination with your social security number; driver’s license number, driver authorization card number or identification card number; account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to your financial account; medical identification number or a health insurance identification number; user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account.

Additionally, you may review and request that we change the personally identifiable information that we collect about you on our websites or other online services by emailing us at KohlerGlobalDataPrivacy@kohler.com.

Our service providers and other third parties may collect personally identifiable information about your online activities over time and across different internet websites or online services when you use our Websites or online services.


 

EUROPEAN ECONOMIC AREA SPECIFIC PRIVACY RIGHTS


If you are resident in the European Economic Area, under European law you have the following rights in respect of your personal information that we hold. If you wish to exercise one of these rights, please contact us at KohlerGlobalDataPrivacy@kohler.com.

You also have the right to lodge a complaint to your local data protection authority.

Residents in other jurisdictions may also have similar rights to the above. Please contact us at KohlerGlobalDataPrivacy@kohler.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

Right of Access

You have the right to obtain confirmation of whether, and where, we are processing your personal information; information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; information about the categories of recipients with whom we may share your personal information; and a copy of the personal information we hold about you.

Right of Portability

You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

Right of Erasure

You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

Right to Restriction

You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

Right to Object

You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

Residents of France

If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.


 

CHINA PRIVACY NOTICE ADDENDUM


Content TBD
 

BRAZIL RESIDENTS’ RIGHTS


Content TBD
 

PERSONAL INFORMATION

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OTHER INFORMATION/ANONYMOUS INFORMATION

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AGGREGATE INFORMATION

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MINORS

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IP ADDRESS

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DATA COMPTROLLER

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