NEWELL BRANDS PRIVACY STATEMENT

Last Modification: November 13, 2024 (V3.5)

TOPICS:

1. Your Privacy is Important to Us
2. Personal Information We Collect About You
3. Why We Process Your Personal Information, Legal Bases for Processing and Retention
4. How We Disclose Your Personal Information
5. International Data Transfers
6. Your Rights Regarding Access to and Control Over Personal Information
7. For California Residents Only
8. Sensitive Personal Information
9. Personal Information Submitted by Children
10. Cookies, Web Beacons and Other Tracking Technologies
11. Security
12. Links to Third-Party Sites
13. Using Mobile and Other Devices
14. Email Marketing Communications
15. Text Messaging
16. Chatbots and Artificial Intelligence
17. Changes to Our Privacy Statement
18. Contact Us
19. Data Controller and Data Protection Contact Information
20. For California Residents Only: Notice of Financial Incentive
21. Updates to Policy

1. YOUR PRIVACY IS IMPORTANT TO US

At Newell Brands, we strive to honor the privacy and security of our users, customers and suppliers, as well as their representatives, in relation to all products, services, applications and websites provided by Newell Brands Inc., or any of its affiliates (“Newell Brands”), when acting as a Data Controller under relevant data protection rules and regulations.

This Privacy Statement describes our privacy practices as required by the EU General Data Protection Regulation (“GDPR”), UK General Data Protection Regulation (“UK GDPR”), California Consumer Privacy Act (“CCPA”) and other applicable data protection laws (collectively “Privacy Laws”). This Privacy Statement applies where Newell Brands is acting as a Data Controller with respect to the Personal Information (which includes “Personal Data” as defined under relevant Privacy Laws) of our customers, employees, website users, partners and service providers. In other words, this Privacy Statement applies where we determine the purposes and means of the processing of Personal Information.

This Privacy Statement provides information regarding how we, when acting as a Data Controller, collect, process, share, transfer, retain and protect Personal Information, and the rights you may exercise, where applicable, regarding your Personal Information.

This Privacy Statement applies to Newell Brands’ websites including, not limited to newellbrands.com, Newell Brands mobile apps, Newell Brands dedicated social media accounts, etc. (“Sites”). This Privacy Statement does not apply to third-party applications, products, services, websites, or social media features that may be accessed through links on our Sites that have their own privacy policies. Accessing those links will cause you to leave our Sites and may result in the collection and/or sharing your Personal Information by a third party. We do not control, endorse, or make any representations about third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy practices of any site you interact with before allowing the collection and use of your Personal Information. If you have any questions or comments regarding this Privacy Statement or our data privacy practices, please contact us at Data Privacy Enquiry.

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU

When you complete a transaction, submit a request, set up an account, apply for a position (Privacy Statement for Job Applicants) , visit our Sites, etc., or interact with any Newell Brands entity, you may be asked to provide certain information, including, but not limited to, your name, title, company, address, phone number, e-mail address, credit card information, and line of business. You may also provide us with data regarding your devices, such as your IP address, your geolocation, your data usage, your client or supplier account, etc. In limited circumstances, we may collect information related to you, and your family members, such as age, gender and civil status. This information and data may be considered Personal Information under applicable Privacy Laws.

We may also collect your information from third-party sites, including when you log in through a third-party site such as Facebook, Snapchat, Instagram, Amazon, LinkedIn, Twitter, etc. We may also disclose information collected from third parties to customize ads and to manage and facilitate messaging on third party sites.

3. WHY WE PROCESS YOUR PERSONAL INFORMATION, LEGAL BASES FOR PROCESSING AND RETENTION

Please consult the table below to see the categories of Personal Information we may collect, why we process (collect, use, store, etc.) such Personal Information, the legal grounds for such processing (where applicable), and the relevant maximum retention period.

If you wish to object to the use of your Personal Information for these purposes, see the “Your Rights Regarding Access to and Control Over Personal Information” in section 6 below.

We will keep your Personal Information while we are providing our products and services to you. Thereafter, we will keep your Personal Information for one of the following reasons: (a) to respond to any questions, complaints or claims made by you or on your behalf; (b) to show that we treated you fairly or in accordance with the law; (c) for the proper administration of our business; and/or (d) as required by law.

We will not retain your Personal Information for longer than necessary for the purposes for which it was collected as set out in this Privacy Statement. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements, and your expectations and requirements. When it is no longer necessary to retain your Personal Information, we will securely delete it or anonymize it in accordance with applicable Privacy Laws. 

 We retain Personal Information generally as follows:

• Identification data - As long as required for the purpose listed above, including: (i) as required in performance of a contract between us; (ii) while you maintain an account with us (and for up to 45 days after you delete your account); or (iii) for 120 days after you last correspondence with us (or until you withdraw consent to direct marketing communications).
• Electronic identification data - As long as required for the purpose listed above, including: (i) as required in performance of a contract between us; (ii) while you maintain an account with us (and for up to 120 days after you delete your account); (iii) for 120 days after you last correspondence with us (or until you withdraw consent to direct marketing communications); or (iv) up to 4 years after you visit our Sites.
• Financial characteristics - If required for the purpose listed above, including: (i) as required in performance of a contract between us; or (ii) while you maintain an account with us (and for up to 45 days after you delete your account).
• Personal characteristics - As long as required for the purpose listed above, including: (i) as required in performance of a contract between us; (ii) while you maintain an account with us (and for up to 45 days after you delete your account); or (iii) for 120 days after you last correspondence with us (or until you withdraw consent to direct marketing communications).
• Image and recordings - As long as required for the purpose listed above, including: (i) as required in performance of a contract between us; (ii) while you maintain an account with us (and for up to 120 days after you delete your account); (iii) for 120 days after you last correspondence with us (or until you withdraw consent to direct marketing communications); (iv) up to 6 months after you visit our premises; or (v) up to 4 years after you visit our Sites.

We also may retain your Personal Information in our records in accordance with our current record retention policy, which is designed to meet our various legal and/or professional retention obligations and commercial best-practices (and may be as long as 10 years).  For more specific information regarding the retention periods, please contact us at Data Privacy Enquiry.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

Your Personal Information may be disclosed to others as described below:

• We may disclose your Personal Information to any member of our group of companies, affiliates, as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Statement.
• We may disclose your Personal Information to the following categories of third parties for the purposes described above.  We may disclose Personal Information to third parties as follows:
• Analytics Providers - We may disclose electronic identification data including product related video viewing history to support our marketing and product development efforts.
• Advertising Networks/Partners – We may disclose electronic identification data and personal characteristics including product related video viewing history to support our marketing efforts.
• Social Networks - We may disclose electronic identification data to support our marketing, consumer service, and product development efforts.
• Insurers and Professional Advisors - We may disclose personal information for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or other legal proceedings.
• Content Providers- We may disclose your Personal Information for the purposes of delivering site content including product related videos.
• Payment Service Providers - We may disclose your Personal Information to complete financial transactions. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
• Fulfilment Partners/Suppliers - We may disclose your Personal Information to complete and send purchase/orders.
• We may disclose your Personal Information within Newell Brands to: (a) complete and send purchases/orders, (b) facilitate payments, (c) manage you interaction with our organization and affiliates, (d) respond to consumer inquiries, (e) address legal or regulatory claims, (f) facilitate marketing, product, service information (g) manage product recalls, (h) train our employees and contractors.
• In addition to the specific disclosures of Personal Information set out in this section, we may disclose your Personal Information: (a) where such disclosure is necessary for compliance with a legal obligation to which we are subject, including a subpoena, court order or search warrant; (b) enforce our Terms of Service, this Privacy Statement, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims regarding violations of third party rights; (d) respond to your requests for customer service; (e) protect the rights, property or personal safety of Newell Brands and its employees, its agents and affiliates, its users and/or the public; and/or (f) with other companies and organizations for fraud protection, spam/malware prevention, or to protect your vital interests or the vital interests of another natural person.

We reserve the right to transfer your Personal Information in the event of bankruptcy or a sale or transfer of all or a portion of our business or assets, an acquisition, merger or divestiture and all due diligence efforts for these items.

5. INTERNATIONAL DATA TRANSFERS

Newell Brands is a global business based in the United States. Newell Brands, and our affiliated companies, have offices and facilities in worldwide locations including, the European Union/EEA, UK, Latin America, Asia and Africa. Your Personal Information may be transferred to other jurisdictions.

Our customers and the users of our Sites may be located anywhere in the world. The Privacy Laws in some countries may not provide protections equivalent to those in your country of residence, and your government may or may not deem such privacy protections adequate. We may process your information in, or transfer your information to, the United States or other countries.

In the event of transfer of Personal Information subject to the GDPR or UK GDPR to a country which has not been deemed to ensure an adequate level of protection for such Personal Information, we will implement appropriate safeguards, which may include further assessments and additional safeguards, in accordance with relevant legal requirements.

6. YOUR RIGHTS REGARDING ACCESS TO AND CONTROL OVER PERSONAL INFORMATION

Depending on the jurisdiction in which you reside and the Privacy Laws applicable to your Personal Information, you may have the following rights, which may require a verified request to exercise:

• Information and Access - You may request to access your Personal Information, receive supplemental information about your Personal Information, receive information on the public and private entities to whom your Personal Information has been provided, and/or be provided with a copy of your Personal Information.
• Rectification - You may request to rectify and/or update your inaccurate or out-of-date Personal Information.
• Erasure- You may have the right to have your Personal Information erased.
• Restriction - You may have the right to restrict the processing of your Personal Information.
• Object to Processing- You may have the right to object to specific types of processing of your Personal Information.
• Data Portability - You may have the right to request a portable copy of your Personal Information. Data Portability does not apply to paper records, and must not prejudice the rights of others, or involve sensitive company information.
• Right not to be subject to decisions based solely Automated Decision Making- You may have the right not to be subject to decisions based solely on automated processing (i.e., without human intervention).
• Right to lodge a complaint- You may have the right to lodge a complaint with a supervisory authority in the country where you reside, where you work, or where the potential infringement took place. For additional information on relevant supervisory authorities, please see section 7 of this Privacy Statement.
• Right to Revoke Consent – You may have the right to revoke previously provided consent related to your Personal Information.

Data subject access requests apply to all individuals regardless of whether your state has passed any privacy laws.

Newell Brands may charge a reasonable fee or reject your request if your request is not valid under applicable law, repetitive or excessive. We may also request information from you to verify your identify before you receive a response. Newell Brands may reject your request if your identity cannot be validated.

If you have any questions about, your rights as it pertains to Newell Brands, please contact us at: Data Privacy Enquiry or by using the contact information provided below.

If you desire to exercise your applicable rights, please complete a Data Subject Access Request.

This Privacy Statement does not create, extend or modify any EU Data Subject rights, UK Data Subject rights, consumer rights under any US State or Newell Brands obligations, except as provided by the GDPR, UK GDPR, CCPA or other applicable Privacy Law.

7. FOR CALIFORNIA RESIDENTS ONLY

To the extent the CCPA (defined below) applies to us, this Section applies to our collection and use of CCPA Personal Information (defined below) as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (CPRA), and the associated implementing regulations (collectively, the “CCPA”). This Section describes (1) the categories of CCPA Personal Information collected and disclosed by us, (2) privacy rights of California residents under CCPA, and (3) how California residents can exercise those rights.

“CCPA Personal Information” means information that that is not publicly available (as such term is defined in the CCPA) that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household

In accordance with California law, we may have used the following categories of CCPA Personal Information within the past 12 months in the following ways:

We collect and process CCPA Personal Information in each of these categories to facilitate our business purposes listed in Section 3 above.

In the last 12 months, CCPA Personal Information may have been sold, shared or disclosed to the following categories of third parties:

• Analytics Providers – CCPA Personal Information was collected by Data Analytics Providers to better understand our customers and prospective customers and to understand and improve effectiveness of marketing efforts; and
• Advertising Networks/Partners – CCPA Personal Information may have been shared to provide customers and prospective customers more relevant advertising.

To opt-out of the selling or sharing of your CCPA Personal Information please click here: DO NOT SELL/SHARE MY PERSONAL INFORMATION

The CCPA considers certain CCPA Personal Information to be sensitive information (“CCPA Sensitive Personal Information”). We do not believe that we use or disclose CCPA Sensitive Personal Information for purposes other than those specified in section 7027(l). In accordance with California law, we may have used the following categories of CCPA Sensitive Personal Information within the past 12 months in the following ways:

 In the last 12 months, CCPA Sensitive Personal Information may have been disclosed for the following business purpose to the following categories of third parties:

• Analytics Providers - To understand and improve effectiveness of marketing efforts by general location.

If you are a resident of California, you may have the following rights:

• Notice – You may have the right to be notified of what categories of CCPA Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
• Access – You may have the right to request the categories of CCPA Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of CCPA Personal Information we have collected about you, and the business purposes for which such CCPA Personal Information is collected and shared. You may also have the right to request the categories of CCPA Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your CCPA Personal Information.
• Data Portability – You may have the right to receive the CCPA Personal Information you have previously provided to us.
• Erasure – You may have the right to have your CCPA Personal Information deleted. However, please be aware that we may not fulfil your request for deletion if we (or our service provider(s)) are required or permitted to retain your CCPA Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the CCPA Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your CCPA Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
• To Opt Out of Sale or Sharing - The right to opt out of the sale or sharing of your CCPA Personal Information.
• Limit use of Sensitive Personal Information - The right to limit the use of your CCPA Sensitive Personal Information for any purpose other than what is specified in CCPA Regulations section 7027(m).
• Non-Discrimination - Businesses cannot deny goods or services, charge a different price, or provide a different level or quality of goods or services to those exercising their rights under the CCPA. However, if you refuse to provide your personal information to a business or ask it to delete or stop selling your personal information, and that personal information or sale is necessary for the business to provide you with goods or services, the business may not be able to complete that transaction.

If you are a CA resident and you would like to exercise rights you may have listed above, please contact us (or your authorized agent) by utilizing the Data Subject Access Request form. We will not discriminate against you in any way for your exercise of any CCPA rights.

We may need to verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification. We may deny certain requests, or only fulfil some in part, as permitted or required by law. For example, if you request to delete CCPA Personal Information, we may retain such CCPA Personal Information that we need to retain for legal purposes (e.g., tax accounting).

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 18.

8. SENSITIVE PERSONAL INFORMATION

Unless specifically requested by us or required by law, we ask that you not send us, and you not disclose, on or through the Sites or otherwise to us, Sensitive Personal Information, which may include, depending on the jurisdiction and without limitation, your religion, ethnicity, political opinions, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions.  The requirements for collecting and processing Sensitive Personal Information vary by jurisdiction, but in the event, we collect or process Sensitive Personal Information, we will abide by all applicable Privacy Laws.

Legal grounds for processing Sensitive Personal Information may include consent, legal obligation, and/or support legal defense claims.

9. PERSONAL INFORMATION SUBMITTED BY CHILDREN

Some of the content on our Sites may be directed toward children under age 13. However, we do not knowingly collect or solicit personal information from children under age 13 without parental consent, unless permitted by law. If we become aware that we have collected personal information from a child under age 13 without parental consent or unless otherwise permitted by law, we will delete it in accordance with applicable law. If you believe that a child may have provided us with Personal Information without parental consent or as otherwise not permitted by law, please contact us as detailed below in the “Contact Us” section.

California Consumers – Our sites and services directed toward children will verify a user’s age and offer choices regarding the sale of personal information related to children aged 16 or younger. If a California consumer is under 13 years old, a parent or guardian must consent to the sale of the minor’s personal information. However, if the California consumer is between the ages of 13 and 16 years old, the minor may provide consent to the sale of their personal information. Our sites directed toward children will ask for age verification and require appropriate consent.

EU Residents – We do not collect, or process Personal Information related to EU Data Subjects under the age of 16 or the age requirement for GDPR consent for minors in the relevant EU Member State, without explicit consent from a parent or guardian. Our sites directed toward children will ask for age verification and require consent as appropriate.

10. COOKIES, WEB BEACONS AND OTHER TRACKING TECHNOLOGIES

Our Sites use Cookies and other similar technologies in accordance with applicable Privacy Laws. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies help with a variety of website functions including allowing users to “log in” to websites (making your navigation of websites more efficient), remembering your preferences (such as language), and generally improving your experience on our Sites. Cookies can also help ensure that the advertisements and content you see online are more relevant to you and your interests. We may also include web beacons in marketing e-mail messages or our newsletters to determine whether messages have been opened and links contained within clicked on.  Similar technologies to accomplish similar goals may include, pixels, web beacons, JavaScript and any other means of storing or accessing information on the device.

Additionally, our Sites may be configured to recognize general global privacy control (“GPC”) or Do Not Track (“DNT”) signals from most browsers’ settings. As not all browsers and extensions have a standard signal it may be possible that your specific GPC or DNT signal is not technically recognized by our Sites. For more information, please see our Cookie Policy.

11. SECURITY

There is no perfect security. We have implemented appropriate and commercially reasonable organizational, technical, and administrative safeguards to protect Personal Information. You are responsible for maintaining the secrecy of any credentials that can be used to access any account or service with Newell Brands. If you should suspect any unauthorized activity, please report this to us immediately. You can report suspicious activity or other concerns by contacting us at Data Privacy Enquiry.

12. LINKS TO THIRD-PARTY SITES

We are not responsible for the practices employed by any websites or services linked to or from the Sites, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

13. USING MOBILE AND OTHER DEVICES

Newell Brands, our affiliates and third parties that we have engaged, may collect and store unique identifiers matched to your mobile device to deliver customized ads or content while you use our Sites or navigate the internet to deliver location-based services and advertising, or to identify you in a unique manner across devices or browsers. To customize these ads or content, we, or third parties, may collect Personal Information, e.g., your email address, or data passively collected from you such as your device identifier, location, or IP address. Your mobile devices may allow you to turn off location services or otherwise restrict what data is provided when you use our Sites or navigate the internet.

By adjusting the privacy and security settings on your device, you can manage how your mobile device and mobile browser share information, as well as how your mobile browser handles Cookies and other tracking identifiers. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

14. EMAIL MARKETING COMMUNICATIONS

If, where required by applicable law, you have provided consent, or otherwise if you have not directed us not to send you marketing messages, we may send you marketing messages via email and/or mail to keep you updated on our products and services.

You can stop receiving marketing messages from us at any time through the following methods:

• Through your customer account settings/preferences within “My Account”
• By clicking on the ‘unsubscribe’ link in any email communication we send you
• By contacting Consumer Care
• By contacting us at: Data Subject Access Request

Once one of these methods is completed, we will honor your request and update your profile to ensure that you don’t receive further marketing messages.

We will process opt-out/unsubscribe requests as quickly as possible in accordance with applicable Privacy Laws, and in most cases, within 10 days. However, Newell Brands consists of many entities and associated service providers so it may take time for all our systems to reflect these updates. We ask for your understanding that during this period you may still get messages from us while your request is being processed.  Please note that when you unsubscribe from our marketing email there may be a delay in the discontinuation of our ads directed to you on third party sites. 

Please note that the discontinuation of marketing messages will not stop any service communications such as order updates.

15. TEXT MESSAGING

Our Sites may give you the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you have shared with us. Once you have opted-in, we may send you text messages regarding your account, to investigate or prevent fraud, to alert you in the event of an emergency, etc. We may send you text messages and alerts using autodialing technology. Also, from time to time, we may run certain campaigns that provide you with the ability to send a text message to a specific short code and provide an opt-in to receive future text messages. Your opt-in request provides us with your mobile phone number. If you choose to opt-in, you agree that we may, from time to time, send messages to the mobile device associated with that number about new products, promotions, services, or offers. These text messages may use cookies to personalize your experience (e.g. send you personalized messages such as shopping cart reminders or to inform you of deals on products you’ve added to cart).

You may choose to opt-out from our text messages and alerts at any time by replying “STOP” to the message you received. Once you opt-out, you will not receive any additional text messages via your mobile phone. Please keep in mind that if you opt-out of receiving text messages and alerts we may not be able to contact you with important messages regarding your account or transactions with us. However, if there is an emergency or account question, we will make every attempt to contact you in other ways such as by email or on a landline phone. You do not have to opt-in to text messages and alerts to use our Sites and services. If you opt-in, standard text messaging charges may apply. For more information regarding our text messaging and alerts, please contact us at Data Privacy Enquiry.

16. Chatbots and Artificial Intelligence

We may use chatbots with Artificial Intelligence (AI) to facilitate communication with you and address your inquires. When you interact with our AI and chatbots, we may collect data such as your name, email address, and phone number. We use this data to provide personalized recommendations, address your inquires, provide you service, and improve our products. These conversations may be recorded and shared with our service providers to ensure we are best serving you and others.

You have the right to access, correct, or delete your data. You can also object to the processing of your data or request that we restrict the processing of your data. To action these rights, you can submit through our Data Subject Access Request form.

17. CHANGES TO OUR PRIVACY STATEMENT

We reserve the right, at our sole discretion, to change, modify, add, or remove portions from this Privacy Statement at any time. We shall notify any such changes in accordance with applicable Privacy Laws.

Any material changes to this Privacy Statement will be posted on this webpage. Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Sites. It is your responsibility to review our Privacy Statement each time you provide Personal Information to us as the Privacy Statement may have changed since the last time you used our Sites or services.

18. CONTACT US

If you have questions about this Privacy Statement or Newell Brand’s practices, please contact us at Data Privacy Enquiry.

19. DATA CONTROLLER AND DATA PROTECTION CONTACT INFORMATION

You can find a list and contact details of Newell Brands Data Controllers and more information related to Supervisory Authorities, on the following page: Newell Brands Data Controllers and EU Supervisory Authorities.

Where the Newell Brands Data Controller is located outside of the EU/EEA/UK, the Controller’s EU/UK Representative is specified on the Newell Brands Data Controllers and EU Supervisory Authorities page.

Newell Brand’s Director of Data Privacy may be contacted at:

Data Privacy Enquiry

Or
Attn: Data Protection Director
6655 Peachtree Dunwoody Road
Atlanta, Georgia 30328

Toll-free number: 800-777-5452

For more information on the full extent of your rights or to exercise your rights, please contact our Data Protection Director using the contact information above or data.privacy@newellco.com or the lead supervisory authority for Newell Brands in the EU, namely The Director of the Personal Data Protection Office UODO of ul. Stawki 2, 00-193 Warsaw, Poland, www.uodo.gov.pl.

20. For California Residents Only: Notice of Financial Incentive

You have the right to receive equal service and price and not be discriminated against for exercising any of your CCPA rights. The CCPA also allows us to offer certain financial incentive programs that may result in different prices, rates, or quality levels when consumers make purchases through these programs. When you sign up for these programs, we will ask you to provide your contact information, email address or phone number to receive messages that include information about the programs. Your contact information, email address and phone number are personal information, and the value of your personal information to us is related to the value of the free or discounted products that you obtain in connection with these programs, and it is based on the expense related to offering those free or discounted products or services. Before we save your contact information, email address and/or phone number to our databases or send you any promotion offer, you will be presented with the opportunity to opt-in to the program. You may withdraw from participating in these programs at any time.

We may from time to time offer rewards programs, benefits, and other offerings to consumers related to the collection, retention, or sale of Personal Information that may be deemed a “financial incentive” or “price or service difference” under the CCPA.

We are providing you with this information so that you may make an informed decision on whether to participate in our programs.

Examples of the programs we may offer include:

• Reward Program - We may offer a program where customers can earn rewards, accumulate points on purchases, and discounts on purchases. As part of the program, we may collect Personal Information, such as your name, email address, phone number, and date of birth.
• One-Time Promotions - We may offer you one-time percentage off coupons, discounts, or other promotions from time to time, such as when you provide us your email address and agree to receive marketing emails in exchange for a one-time coupon or when you provide an email address as a referral. Such offers may not be always available. The amount and terms of such offers will be presented to you at the time of the offer.

The value of the benefits we provide to you via these programs depends on various factors, including the benefits and insights that we realized when you use our services and buy our products, sales generated from participation in our programs, whether the sales generated by our programs exceed the costs to us of offering such programs, how many consumers sign up for our programs, and increased goodwill generated from provision of our programs.

Participation in our promotional programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms, or by contacting us at Data Privacy Enquiry.

We may communicate with you via an automated online account where all or substantially all of the actions or posts of that account are not the result of a person (a “Chatbot”).  We may use such Chatbots to help provide you service and address your queries.  Such Chatbot features may also record any conversations between you and the Chatbot to help ensure we are best serving you and other users.

21. Updates to Policy

1. June 20, 2023
2. July 20, 2023
3. September 19, 2023
4. December 21, 2023
5. November 13, 2024