Effective Date: October 4, 2021
Effective Date: October 4, 2021
This Notice covers our collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding the Effective Date. This Notice also covers rights California Consumers have under the CCPA, as well other notices to Californians that may be required by certain other laws.
Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
We hereby give you notice that, within the past 12 months, we have collected the following types of PI about California Consumers, with exemplary elements of PI listed. This notice will be updated annually, and our current privacy notices at the point of collection and general privacy statements may reflect more current practices.
Category of PI
Examples of PI
This may include but is not limited to: contact information (such as name, address, city, state, province/territory, Postal/ZIP code, email address and telephone number), IP address, device identifier, alias/account name, and in limited circumstances, state ID number, cosmetology license number, business tax ID, and other identifiers for professional use.
2. Personal Records under Cal. Civil Code § 1798.80(e)
This may include information such as: identifiers described above, date of birth, and other personal, financial, and consumer complaint information.
3. Characteristics of Protected Classifications
This may include but is not limited to demographic information such as gender or age.
4. Commercial Information
This may include but is not limited to: customer account details, products or services purchased or considered, service history, other purchasing or consumption histories or tendencies, and transaction records.
5. Internet and other Electronic Network Activity Information
This may include but is not limited to: information about your use of our sites, apps, or services, information regarding your interaction with Henkel sites and mobile apps and advertisements displayed on Henkel or third party sites and apps, and data regarding network connected hardware, browsing activity, IP address, and device identifiers.
6. Geolocation Data
This may include but is not limited to: physical location.
7. Audio, Visual, or other Sensory Data
This may include but is not limited to: customer-submitted photographs, videos, and audio.
8. Professional or Employment-related Information
This may include but is not limited to: information from resumes or cover letters, third-party employment status, employment history, background screening information, and professional licenses.
9. Inferences from PI Collected
These may be drawn from any of the categories of information listed above, and/or from any other information we process, and may include (but is not limited to): consumer preferences, aptitudes, attitudes, trends, characteristics, predispositions, and behavior, including in connection with profiles created about consumers.
A. Sources of PI.
We may collect your PI directly from you or your device, or from service providers, vendors and suppliers, our affiliates, or other individuals and businesses as well as public sources of data.
B. Use of PI.
In addition, we may collect, use and share the PI we collect for one or more of the following business purposes:
Within the 12 months preceding the Effective Date of this Notice, we did not “sell” PI as defined under the CCPA. For more information, see Section 3(C) (“Do Not Sell” Requests) below.
We provide California Consumers the privacy rights described in this section. You may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA. As required by the CCPA, any request you submit to us is subject to a verification process. We may not fulfill your CCPA request unless you have provided sufficient information for us to appropriately verify you and your request. Please follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make. You may also submit a request by calling us at 1-888-285-1935.
You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We will typically not charge a fee to respond to your requests; provided, however, that we may charge a fee if permitted under applicable law. The California Consumer privacy rights outlined in this Notice, and our obligation to fulfill requests to exercise them, may be subject to limitations and exceptions as permitted or required by law.
Your California Consumer privacy rights are as follows:
A. The Right to Know and Have Access to Data
You have the right to make or obtain a copy of your PI that we have collected in the period that is 12 months prior to the request date. To make a request, follow the instructions at our Consumer Rights Request page here or call us at 1-888-285-1935.
B. Right to Delete
You may request that we delete your PI that we have collected from you. Please note that even if you make a request to delete your PI, applicable law may permit or require us to retain that was collected to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.
To make a request, follow the instructions at our Consumer Rights Request page here or call us at 1-888-285-1935.
C. “Do Not Sell” Requests
We do not believe that during within the year prior to the Effective Date of this Notice, that we “sold” your PI as such is defined under the CCPA. Similarly, we do not knowingly sell the PI of Consumers under 16.
Even though Henkel does not currently “sell” PI, Henkel generally reserves the right to “sell” PI as defined under the CCPA in the future. We offer consumers the option to prospectively opt-out of any such future “sales” of PI. To do so, click here and submit a “Do Not Sell” request. Again, Henkel does not currently “sell” PI as defined under CCPA, and making this “Do Not Sell” request will only have effect if Henkel in the future decides to “sell” PI.
However, we offer users of our websites the ability to control whether certain cookies and similar technologies on our website share information about them. You can manage whether your browser permits certain cookies and other Tracking Technologies in your browser settings, or you can review the types of cookies that are used on a site by selecting the “cookies” link on the applicable site and deactivating the types of cookies you do not want active.
However, you may alternatively exercise more limited control of your PI by instead exercising one of the following more limited opt-outs: for promotional emails, following the opt-out instructions provided in email communications, 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.
D. Non-Discrimination and Financial Incentive Programs
As required by the CCPA, we will not discriminate against you because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale, retention and use of your PI as permitted by the CCPA.
E. Authorized Agents
Authorized agents of Consumers may make a request by visiting here or calling 1-888-285-1935. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process, and confirmation of the agent’s authority, which may include attestation under penalty of perjury.
In addition to CCPA rights, certain Californians are entitled to certain other notices, including:
A. Third Party Marketing and Your California Privacy Rights
Although as of the Effective Date of this revised Notice it was not Henkel’s current practice to share your “personal information” as defined by California’s “Shine the Light” law with third parties, other than Henkel affiliated companies and subsidiaries, for such third parties’ own direct marketing purposes without your consent, we reserve the right to do so. Accordingly, we provide California residents with the option to prospectively opt-out of our sharing of such data for those purposes to third parties other than Henkel affiliated companies and subsidiaries. To do so, contact Henkel at PrivacyNA@henkel.com, or send a letter to Henkel at:
Attention: Henkel Privacy Inquiries
Privacy Officer Department
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, by law, 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. User-Generated Content Rights for California Minors
Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us here, detailing where the content or information is posted and attesting that you posted it. We will then make 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. Please note that this removal process may not be able to ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
For more information on your California privacy rights contact us at 1-888-285-1935 or email us at PrivacyNA@henkel.com. You may also use our California Consumer Rights Portal found here. Or, write to us at:
Henkel Privacy Inquiries
One Henkel Way
Rocky Hill, CT 06067