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    Kohler Konnect Privacy Policy

    Last Updated : 2024-12-1

    Last Published : 2024-12-1

    Kohler Konnect App (“Kohler Konnect” or the “App”) is a mobile application provided by Kohler (China) Investment Co., Ltd. (registered at No. 158 Jiangchang 3rd Road, Shibei High-Tech Park, Jing’an District, Shanghai) and its affiliates (collectively, “Kohler”, “We”, “Us” or “Our”). The App is designed to offer consumers and users (the “User(s)”, “You” or “Your”) convenient access to Kohler’s smart product services (the “Services”), allowing the User to remotely connect to Kohler’s smart products to which the Services apply (the “Products” or the “Smart Devices”, including smart scales, smart toilets, bathtubs, shower products, water purification systems, bathroom heaters, steam shower, smart mirror cabinets, smart bidet-seat, lithocast vessel, bathroom furniture, mirror, faucets, flood sensor, Kohler smart gateway) via the App to control the Products or access other related Services.

    We attach great importance to the protection of your personal information and privacy. Therefore, we hope this Kohler Konnect Privacy Policy (this “Policy”) will help you better understand how we process your personal information in connection with your use of our Products or Services, as well as the rights you have. Before using our Products or Services, we advise you to carefully read and fully understand the content of this Policy (particularly the bolded clauses that are material to your legitimate interests), so that you can make a choice you deem appropriate.

    If you have any questions, suggestions, or recommendations, you can contact us using the information provided in the “How to Contact Us” section of this Policy.

    This Policy will help you understand the following:

    I. How We Collect and Use Your Personal Information

    II. How We Use Cookies and Similar Technologies

    III. How We Entrust to Process, Share, Transfer, and Publicly Disclose Your Personal Information

    IV. How We Store and Protect Your Personal Information

    V. Your Rights

    VI. How We Process Minors’ Personal Information

    VII. How Your Personal Information Is Transferred Worldwide

    VIII. How We Update This Policy

    IX. How to Contact Us


    I. How We Collect and Use Your Personal Information

    According to the Rules on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications, Kohler Konnect belongs to the local life category, its basic functionality includes “daily life services, and smart home control and management”, for which the necessary personal information is :mobile phone number. By agreeing to this Policy, you acknowledge that you understand the basic functionality of our Products and Services, as well as the essential personal information required for their operation, and that you grant us the authority to collect and use your personal information accordingly. However, this does not constitute your consent to our collection and processing of optional personal information. When you use any specific extended feature, we will seek your separate consent for obtaining personal information related to such feature. Your refusal to activate extended functionality and provide optional personal information will not impact your use of the basic functionality. You can view the Personal Information Checklist by navigating to My > Settings within the App.

    (I) Circumstances where you must authorize us to collect and use your personal information

    Below are the basic business features of Kohler Konnect. When using the following basic business features, you may need to provide us with or allow us to collect and use certain of your essential personal information. Refusal to provide the specified personal information may result in denial of access to the corresponding Services. Specific features include:

    1. Signup or Password Change/Resetting

    When signing up for the App or changing/resetting your password, you need to provide us with your mobile phone number or email address and password. We may verify your identity by sending an SMS or email verification code. We collect and use this information to create your personal account so that we can provide you with continuous and stable Services and ensure your secure access to the App.

    2. Login

    When logging into the App, you need to provide us with your mobile phone number or email address and account password, which helps us verify your identity and grant access to your account.

    3. Smart Devices Connection and Management

    To enable the connection to and management of your Smart Devices, we may collect and use your login account information, mobile phone details, IP address, information related to the Smart Devices, and information pertaining to the association between Kohler Konnect and the Smart Devices, when you connect them. This information will be used when you access such features as connecting Smart Devices, discovering nearby devices, and managing Smart Devices. The details are listed below:

    • Mobile phone details: Device identifiers (including Android ID, GAID, OAID, UAID, IDFA, IMEI, MAC, and IMSI), device hardware information (including device type, device screen resolution, device hardware manufacturer, and device product name), operating system information (including operating system version, system name, and system language), network information (including network type, operator name, IP address, Wi-Fi status, SSID, BSSID, Wi-Fi list, and base station information), push notification log, phone model, and system version information;

    • Information collected during connection to the Smart Devices: Depending on the type of the Smart Devices you need to connect to, we may collect the following information:

    o For the Smart Devices with Wi-Fi connection: Wi-Fi information (SSID, BSSID, Wi-Fi Mac address, and Wi-Fi password), device Mac address, device ID, device SN code, and network status;

    o For the Smart Devices with Bluetooth connection: Device Bluetooth Mac address, signal intensity, device ID, and device SN code.

    4. Help & Feedback

    When you contact us using the contact information stated in this Policy or provided in the App, we may selectively record your contact details, name, account number, and the content of our conversation with you. This information is used to verify your identity and assist you in addressing any concerns.

    (II) Circumstances where you can decide whether to authorize us to collect and use your personal information

    To enhance your experience of the control and management of your Smart Devices provided by Kohler Konnect, we may collect and use your personal information for the extended features listed below. If you choose not to provide this personal information, you can still access the basic functionality of Kohler Konnect. However, you may not be able to use the extended functionality that could offer additional convenience. These extended features include:

    1. Providing You with Kohler Wellness Services

    Kohler Wellness (“Kohler Wellness”) is a component of the App. Kohler Wellness can control and manage applicable Smart Devices, display health information (i.e., health-related data imported from the connected Smart Devices with your authorization and consent), or provide other related Services (collectively, “Kohler Wellness Services”). To better provide you with Kohler Wellness Services, subject to applicable laws, regulations, and regulatory requirements, we will collect and process your personal information in the following scenarios:

    Personal health information management: To help you better understand your basic health condition, improve the accuracy of health information computation, and provide you with specified health management services, you can provide us with certain of your health information, including gender, date of birth, height, weight, or menstrual cycle. Your refusal to provide this information may impact the accuracy of health information computation, or prevent you from accessing certain health management features, but it will not impact your use of the basic functionality of Kohler Konnect.

    Health information recording and display: After you connect to applicable Smart Devices and grant your authorization and consent, we will collect the health-related information imported from the connected Smart Devices for recording and display on the Kohler Wellness page. The content of health information collected depends on the data collection capabilities of the Smart Devices and requires your prior authorization and consent. If there are any changes or additions to applicable Smart Devices or the types of personal information collected, we will notify you again and seek your separate authorization and consent:

    (1) Kohler Smart Scale: With your authorization and consent, and after connecting to the Kohler Smart Scale, we will collect your weight measurement data, including weight, body fat percentage, heart rate, BMI, water percentage, muscle mass percentage, metabolic rate, bone mass, protein percentage, visceral fat, subcutaneous fat, lean body mass, body age, and body condition score. Your refusal of consent may make you not able to experience the full functionality of the Kohler Smart Scale, the current weight measurement date (limited to weight and heart rate) generated by the Kohler Smart Scale can only viewed on the relevant smart mirror cabinets products.

    2. Upgrading Smart Devices

    To perform firmware upgrades for Smart Devices and conduct business operation analyses, we need to collect and use the following information: Device identifiers of the connected device (including Device ID and SN), device hardware information, basic application details, and upgrade package type. This information will be used for testing and downloading new versions. You can view firmware upgrade information and perform upgrades by navigating to My > Settings > Firmware Upgrade within the App.

    Kohler Konnect only guides you through the device upgrade process. The device firmware version is provided by the device manufacturer, who is responsible for the version quality and the upgrade outcome.

    3. Scenario Management, Family Group Management and Smart Devices Sharing

    To manage scenarios specific to Smart Devices, family groups and share Smart Devices, we need to collect and use the following information: Kohler Konnect account details, shared account information you provide, device identifiers (including Device ID), device name, scenario settings, family group management details, and family member information (including username, account number and profile picture of any family member with a Kohler Konnect account). This information will be used for setting scenarios, managing family groups, sharing Smart Devices, and accepting sharing invitations for Smart Devices. We will collect and use this information only when you use features such as scenario management, family group management and Smart Devices sharing.

    (III) Device Permission Usage

    In addition, your use of Kohler Konnect may trigger the following device permissions. To help you better manage your information, we will inform you of the purpose of each permission during the permission request process and the potential impact on your service experience if you do not enable it. Please review this information carefully. Before using any specific features, you can choose whether to grant the following permissions. You can also change your permission settings at any time through the device’s permission settings page or by navigating to My > Settings > System Permissions Management within the App. After the relevant permission is off, we will cease accessing it, and will no longer be able to provide the corresponding Services. However, this will not impact our prior processing of the information based on your authorization.

    Below are the details of relevant features and permissions for your reference:

    1. Location Permission (for Android and iOS versions): Used to provide features such as device automation, retrieving WLAN and Bluetooth lists during quick connections, and discovering nearby devices.

    2. Camera Permission (for Android and iOS versions): Used to scan QR codes for adding devices, and to take profile pictures;

    3. WLAN Permission (for Android version): Used to connect to Wi-Fi signals emitted by devices during quick connections for device communication;

    4. Bluetooth Permission (for Android and iOS versions): Used to connect to Bluetooth signals emitted by devices during quick connections for device communication; Bluetooth permission is also needed for communication with Smart Devices connected via Bluetooth;

    5. Photo Library Permission (for Android and iOS versions): Used to read and write pictures on the device for profile picture changes, and to save images shared by Kohler Wellness.

    6. File Reading/Writing Permission (for Android and iOS versions): Used for saving and reading files related to device plugins, product demo plugins, scenario plugins.

    7. Notification Permission (for Android and iOS versions): Used to send notifications to the Users to keep them informed about the latest news and important events.

    8. Health Permission (for iOS version): Used to share Kohler Wellness weight data with the “Health” app on iOS.

    9. Clipboard (for Android and iOS versions): To enhance the experience of Users, the App may read the content of clipboard to automatically paste text, such as SMS or link. We will not save or share the content from your clipboard.

    (IV) You are fully aware that our collection and use of your personal information do not require your consent if it is necessary:

    1. To enter into and perform the contract to which an individual is a party;

    2. To perform legal duties or obligations;

    3. To respond to public health emergencies, or to protect the life, health, and property of individuals in case of an emergency;

    4. To process personal information for news reporting or public scrutiny in the public interests to the extent it is reasonable;

    5. To process personal information that has been publicly disclosed by individuals or otherwise publicly disclosed by law to the extent it is reasonable;

    6. Any other circumstances provided by applicable laws and regulations arise.

    Please be advised that any information that cannot identify you personally, whether independently or in combination with other information, does not constitute your personal information in the legal sense.

    II. How We Use Cookies and Similar Technologies

    Cookies and similar device information identifying technologies are commonly used on the Internet. When you use our Services, we may employ related technologies to send one or more Cookies or anonymous identifiers (“Cookies”) to your device to collect, track, and store the information as you access and use the Products. This helps us understand the provision of the Services and ensure the security of the Products and the Services. We undertake not to use Cookies for any purpose other than those described herein.

    III. How We Entrust to Process, Share, Transfer, and Publicly Disclose Your Personal Information

    (I) Entrusted Processing

    Certain modules in this business feature are provided by external suppliers. We will engage service providers to assist with customer support. We will enter into agreements with any company, organization, or individual we entrust with the processing of personal information, requiring them to process such personal information in accordance with our requirements and this Policy, and by implementing relevant confidentiality and security measures.

    (II) Sharing

    Except under the following circumstances, we will not share your personal information with any other person. You can view the List of Third Parties with Whom We Share Data by navigating to My > Settings within the App.

    1. Sharing with explicit consent: With your explicit consent, we will share the information you authorize with any third party you designate.

    2. Sharing required by law: We may share your personal information with any third party as provided by laws or regulations, needed for litigation or dispute resolution, or required by administrative or judicial authority in accordance with the law.

    3. Sharing with our affiliates: For any business that uses the same account system, we will share your account information (including account number, and mobile phone number) among our affiliates. However, we will only share necessary personal information. Solely for the purposes stated in this Policy, if we need to share your sensitive personal information, or if our affiliates change the intended use or purpose of processing of your personal information, we will seek your authorization and consent again. (The term “affiliate”, with respect to any entity, means any other legal or non-legal entity that, directly or indirectly, controls, is controlled, or is under common control of such entity; the term “control” means the direct or indirect ownership of a majority of the equity or voting interests of an entity, or the ownership of less than a majority of the equity or voting interests while exercising substantial control over the entity’s financial and business policies, whether through ownership of equity or voting interests, or pursuant to articles of association or other documents or agreements of the entity.)

    4. Sharing with authorized partners: Certain Services will be provided by our authorized partners solely for achieving the purposes stated herein. We may share certain of your personal information with authorized partners to enhance customer services and user experience. However, we will share your personal information solely for legitimate, rightful, necessary, specified, and explicit purposes, as required to provide Services. Our partners are not entitled to use the personal information we share for any other purpose. Our partners include: suppliers, service providers, and other partners. We send information to suppliers, service providers and other partners who support our business operations. This support includes providing technical infrastructure services, analyzing the usage mode of our Services, measuring service effectiveness, offering customer services, facilitating payments, or conducting academic research and investigations.

    5. Sharing your personal information by embedding third-party code plugins

    The App may include SDKs or other similar applications provided by third parties, so that you can enjoy and use the Services and features provided by these third parties. The third-party SDKs that involve personal information sharing and are integrated into Kohler Konnect are listed below. For details on the third-party Services and the personal information required to be collected for providing these Services, please refer to the privacy policies provided in the respective SDKs.

    (1) JPush SDK

    Information Used: Device identification information (including Android ID, GAID, OAID, UAID, IDFA, IMEI, MAC, and IMSI), device hardware information, operating system information, network information, and push notification log

    Information Type: Device information, network information

    Name of Organization: Shenzhen Hexun Huagu Information Technology Co., Ltd.

    Shared Type: Embedded SDK (JPush SDK)

    Purpose: Push notification services

    Usage Scenario: Push notification to Users

    Required System Permissions: Network permissions

    Share Mode: SDK integration

    Link to Official Website: http://www.jiguang.cn

    Link to Privacy Policy: http://www.jiguang.cn/license/privacy

    (2) WeChat Sharing SDK

    Information Used: Device identification information (IMEI (for Android Q and earlier versions]/OAID, IMSI, MAC address, and Android ID), and network information

    Information Type: Device information, network information

    Name of Organization: Shenzhen Tencent Computer Systems Co., Ltd.

    Shared Type: Embedded SDK (JPush SDK)

    Purpose: Support WeChat sharing

    Usage Scenario: The scene when users use the WeChat sharing function

    Required System Permissions: Album permissions, network permissions

    Share Mode: SDK integration

    Link to Official Website: http://weixin.qq.com

    Link to Privacy Policy: http://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy

    (3) Tencent Browsing Service SDK (for Android version)

    Information Used: Application information, Wi-Fi status and parameters, IP address, and AndroidID

    Information Type: Network information, application information

    Name of Organization: Shenzhen Tencent Computer Systems Co., Ltd.

    Shared Type: Embedded SDK (Tencent Browsing Service X5 Web Engine SDK)

    Purpose: Optimizing the User’s browsing experience by using the Tencent X5 engine to render webview

    Usage Scenario: The scene when Android users browse web content

    Required System Permissions: Network permissions

    Share Mode: SDK integration

    Link to Official Website: http://x5.tencent.com

    Link to Privacy Policy: http://x5.tencent.com/docs/privacy.html

    (4) AiJiami Security Enhancement Framework

    Information Used: N/A

    Information Type: N/A

    Name of Organization: Beijing Zhi You Wang An Technology Co. Ltd.

    Shared Type: Embedded SDK (AiJiami Security Enhancement Framework SDK)

    Purpose: A security enhancement solution for Android applications. Provides a series of protection mechanisms to enhance application security and prevent risks such as decompilation, cracking, and tampering.

    Usage Scenario: Application hardening

    Required System Permissions: N/A

    Share Mode: N/A

    Link to Official Website: http://www.ijiami.cn

    Link to Privacy Policy: http://www.ijiami.cn/privacypolicy/privacypolicy.html

    (5) PhoneGap Barcode scanner plugin

    Information Used: Camera preview data, scan result data

    Information Type: Camera information, scanning information

    Name of Organization: Adobe Systems Inc.

    Shared Type: Embedded SDK (PhoneGap Plugin BarcodeScanner)

    Purpose: Provide barcode and QR code scanning functions, supporting recognition of multiple barcode formats

    Usage Scenario: The scene when users use the scanning function

    Required System Permissions: Camera permissions

    Share Mode: SDK integration

    Link to Official Website: http://github.com/phonegap/phonegap-plugin-barcodescanner

    Link to Privacy Policy: http://www.adobe.com/privacy/policy.html

    We will enter into agreements with any company, organization, or individual with whom we share personal information, requiring them to process such personal information in accordance with our requirements and this Policy, and by implementing relevant confidentiality and security measures.

    (III) Transfer

    We will not transfer your personal information to any company, organization, or individual, except that:

    1. We will transfer your personal information to any third party after obtaining your explicit consent;

    2. In the event of a consolidation, acquisition, asset transfer, bankruptcy liquidation, or other similar transactions involving the transfer of your personal information, we will require the surviving company or organization possessing your personal information to continue to be bound by this Policy. Otherwise, we will require such company or organization to seek your separate authorization and consent.

    (IV) Public Disclosure

    We will publicly disclose your personal information only if:

    1. You have explicitly consented to the disclosure; or

    2. The disclosure is required by law. We may publicly disclose your personal information as required by laws, legal proceedings, lawsuits or competent government authorities.

    IV. How We Store and Protect Your Personal Information

    (I) Personal Information Storage

    1. Storage Period: We will store your personal information only for as long as necessary to achieve the purposes stated herein and as long as provided by law or regulations. After the retention period of your personal information is exceeded, we will delete or anonymize your personal information in accordance with the relevant requirements of applicable laws. After fulfilling the collection purpose, confirming your deletion or cancellation request, or discontinuing the operation of the corresponding Products or Services, we will cease collecting and using your personal information, unless otherwise provided by laws and regulations or regulatory authorities, and will delete or anonymize your personal information we hold about you in accordance with the law and regulations.

    2. Place of Storage: The personal information we collect and generate within the PRC (excluding Hong Kong, Macau, and Taiwan) will be stored within the PRC (excluding Hong Kong, Macau, and Taiwan).

    (II) Personal Information Protection

    To ensure the security and integrity of your personal information, we endeavor to implement a range of internal policies and technical security measures that adhere to industry standards, whether physical, electronic, or managerial, to protect your personal information from unauthorized access, public disclosure, use, modification, damage, or loss. These internal policies and technical security measures include: (i) anonymization and encryption of your personal information where appropriate; (ii) procedures and control measures to maintain confidentiality, integrity, availability, and resilience of our processing systems and Services; (iii) procedures and controls to promptly restore personal information availability and access in the event of a physical or technical incident; (iv) procedures for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures to ensure the security of personal information processing; and (v) procedures to prevent data access, excluding access by individuals who have duly performed their duties.

    We will make every effort to protect your personal information. However, you should be aware and understand that no security measure can guarantee absolute safety, and that no product, service, website, data transfer, computer system, or network connection is completely secure. You need to take proper care of your account name, password and other personal information. When you use our Services, we will identify you using this information. Once you divulge this information, you may suffer losses and have adverse legal consequences. If and when you discover any potential or actual disclosure of your account or personal information, please contact us immediately using the contact information provided in this Policy, so we can promptly take corresponding measures to avoid or reduce relevant losses.

    In the unfortunate event of a personal information security incident, we will fulfill our notification obligation in accordance with applicable laws by communicating the following information to you: The basic information about the security incident and its potential impact (including the type of the personal information divulged, lost, or falsified, the cause of the incident, and potential hazards), our remedial measures, and our recommendations for your self-protection and risk mitigation. We will make every effort to promptly notify you via email, push notification, SMS. If it is difficult to notify every personal information subject, we will make an announcement in a reasonable and effective manner. Additionally, we will proactively report the handling of the personal information security incident to the competent regulatory authority as required.

    V. Your Rights

    We guarantee that you exercise the following rights regarding your personal information in accordance with applicable laws, regulations, and standards of the PRC, as well as the common practices of any other countries and regions:

    (I) Right to Access Your Personal Information

    You have the right to access your personal information, except as otherwise provided by laws and regulations. If you desire to exercise the right to access your data, you can do so by the following method:

    You can view profile picture, username, general information (including region, mobile phone number, email address, and password changes), and health information (including gender, date of birth, height, weight, target weight, and menstrual cycle) by navigating to My > User > Personal Data Settings within the App. If you are unable to access your data by this method, or if you need to access other personal information that cannot be accessed in this way, you can call Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users) or send an email to KohlerGlobalDataPrivacy@kohler.com. We will handle your request within fifteen (15) working days or any shorter period (if any) provided by laws or regulations.

    (II) Right to Correct Your Personal Information

    When you need to update your personal information or find any inaccuracies in your personal information processed by us, you can make the update or correction by the following method:

    You can change profile picture, username, general information (including region, mobile phone number, email address, and password changes), and health information (including gender, date of birth, height, weight, target weight, and menstrual cycle) by navigating to My > User > Personal Data Settings within the App. If you are unable to change your data by this method, or if you need to change other personal information that cannot be changed in this way, you can call Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users) or send an email to KohlerGlobalDataPrivacy@kohler.com. We will handle your request within fifteen (15) working days or any shorter period (if any) provided by laws or regulations.

    (III) Right to Delete Your Personal Information

    You can request the deletion of your personal information by calling Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users) or sending an email to KohlerGlobalDataPrivacy@kohler.com if:

    1. Our processing of your personal information violates applicable laws or regulations;

    2. We have collected and used your personal information without your consent;

    3. Our collection of your personal information breaches an agreement made with you;

    4. You no longer use our Products or Services, or you have cancelled your account; or

    5. We cease offering the Products or Services to you.

    We will handle your deletion request within fifteen (15) working days or any shorter period (if any) provided by laws or regulations. If we decide to respond to your deletion request, we will also notify all entities that have received your personal information from us, requesting them to promptly delete such information, except as otherwise provided by laws or regulations or that these entities have obtained your separate authorization.

    After you delete any information from our Services, we may not be able to immediately remove the corresponding information from our backup systems. However, it will be deleted at the time of the next backup update.

    (IV) Right to Cancel Your Account

    You can cancel any existing account at any time by the following method:

    You can cancel your personal account by navigating to My > Settings within the App, then clicking Cancel Account and agreeing to the Account Cancellation Agreement.

    We will handle your cancellation request within fifteen (15) working days or any shorter period (if any) provided by laws or regulations. Upon account cancellation, we will cease offering the Products or Services to you, and will delete or anonymize your personal information upon your request, except as otherwise provided by laws or regulations.

    (V) Right to Withdraw Your Consent

    You can withdraw your authorization and consent at any time for specific Services you use. To do so, you can call Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users) or send an email to KohlerGlobalDataPrivacy@kohler.com or navigate to My > Settings > Legal Information and Privacy Management > Withdraw Your Consent within the App.

    Please be advised that, withdrawing your consent may lead to certain legal consequences. Depending on the scope of the information you have authorized us to process, this may prevent you from accessing the corresponding Products or Services. However, your decision to withdraw consent will not affect any prior processing of personal information based on your authorization.

    Each business function requires some basic personal information to be completed. For the collection and use of additional collected personal information, you can give or withdraw your consent at any time by turning on or off Location Services permissions and Camera permissions, depending on the brand and model of the phone. After you withdraw your consent, the APP will no longer use your personal information. You can also navigate to My > Settings > System Permissions Management within the APP to withdraw your consent made previously in system permissions.

    (VI) Right to Get Copies of Your Personal Information

    If you want to get copies of your personal information, you can make the request by calling Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users) or sending an email to KohlerGlobalDataPrivacy@kohler.com. Subject to applicable laws and regulations, we will provide you with copies of your personal information upon request within fifteen (15) working days or any shorter period (if any) provided by laws and regulations, if technically practicable.

    (VII) Right to Restrict the Automated Decision Making by Information Systems

    In certain mandatory features, we may make decisions solely by virtue of nonhuman automated decision-making mechanisms, including information systems and algorithms. You can make inquiries by calling Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users), or send an email to KohlerGlobalDataPrivacy@kohler.com. If these decisions significantly impact your legitimate rights and interests, you have the right to ask us for an explanation, and we will provide appropriate remedies.

    (VIII) Right to Respond to Your Requests

    If you have any requests, questions, recommendations, suggestions, or complaints, you can call Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users), or send an email to KohlerGlobalDataPrivacy@kohler.com. For security reasons, we will handle the request only after necessary identity verification, and will respond within fifteen (15) working days or any shorter period (if any) provided by laws or regulations.

    For reasonable requests, we generally do not charge a fee. However, for repeated requests that exceed a reasonable limit, we will charge a fee to cover the cost of such requests depending on the circumstances. We may deny any requests that are unreasonably repeated, require excessive technical means (developing a new system or making substantial changes to current practices), pose risks to the legitimate rights and interests of any third party, or are extremely impracticable (involving information stored in backup tapes).

    We may be prohibited from responding to your requests under applicable laws or regulations if:

    1. The request is directly associated with national or defense security;

    2. The request is directly associated with public security, public health, or major public interests;

    3. The request is directly associated with criminal investigation, prosecution, trial, or judgment enforcement;

    4. There is sufficient evidence that you have malicious intent or have abused your rights;

    5. Responding to your request would seriously harm your legitimate rights and interests or those of any other individual or organization; or

    6. The request involves trade secrets.

    VI. How We Process Minors’ Personal Information

    Our Products, websites and Services are primarily intended for adults. No minor shall create an account without the consent of their parent or guardian.

    For personal information collected from a minor with the consent of their parent or guardian, we will use or publicly disclose such information only as permitted by law, explicitly approved by the parent or guardian, or necessary to protect the minors.

    Although the definition of a minor may vary by local laws and customs, we consider any person under the age of 18 to be a minor.

    If we discover that we have collected minors’ personal information without the prior, verifiable consent of their parent or guardian, we will make every effort to delete the relevant data as soon as practicable.

    VII. How Your Personal Information Is Transferred Worldwide

    The personal information we collect and generate within the PRC (excluding Hong Kong, Macau, and Taiwan) will be stored within the PRC (excluding Hong Kong, Macau, and Taiwan). Currently, we have not transferred abroad any personal information generated from your use of Kohler Konnect Services. If we do need to transfer your personal information outside of the PRC due to special reason of business needs, we will fulfill our obligations under applicable laws and regulations and obtain your prior, separate consent.

    VIII. How We Update This Policy

    We will periodically review this Policy based on business and technical changes, and may adjust or update it as appropriate. We will not diminish your rights under this Policy without your explicit consent. Any changes to this Policy will be published on this page. For any significant changes, we will display the updated Policy in a pop-up window when you log in. Please be advised that, we will collect, use, share, and store your personal information in accordance with the updated Policy only after you click the Agree button in the pop-up window. The term “significant changes” referred to herein mainly includes:

    1. Significant changes to our service model, including the purpose of processing personal information, the types of personal information processed, and the methods of using personal information;

    2. Significant changes to our ownership structure, organizational structure, such as changes in ownership resulting from business adjustments, bankruptcy, or M&A;

    3. Changes in the parties involved in the sharing, transfer, or public disclosure of personal information;

    4. Significant changes in your rights to participate in the processing of personal information and the methods for exercising those rights;

    5. Changes in our responsible department for the secure processing of personal information, contact information and complaint channels; and

    6. High risks identified in the personal information security assessment report.

    We will also retain all previous versions of this Policy on file. You can view the latest version and all previous versions of our privacy policy within the App by navigating to My > Settings > Privacy Management > Privacy Policy. We encourage you to review our privacy policy at any time.

    IX. How to Contact Us

    If you have any questions, suggestions, or recommendations regarding this Policy, or if you have any concerns, reports, or complaints about our processing of your personal information, you can contact us by:

    1. Calling Kohler’s customer service hotline (8008202628 for landline users, and 4008202628 for mobile phone users); or

    2. Sending an email to KohlerGlobalDataPrivacy@kohler.com.

    Generally, we will respond within fifteen (15) working days. If you are not satisfied with our response, particularly if you believe our processing of personal information has harmed your legitimate rights and interests, you may also file a lawsuit with the court in the jurisdiction where Kohler is located.

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