This Privacy Statement Regarding Customer and Online User Information (“Privacy Statement”) applies to Wow Kirei Limited Liability Co., and its worldwide subsidiaries* (“WOW KIREI,” “we” or “our”), but not to those WOW KIREI subsidiaries that have published their own privacy and security statements.
This Privacy Statement also does not apply to the websites of our Business Partners (as defined below) or to any other third parties, even if their websites are linked to our website. We recommend you review the privacy statements of the other parties with which you interact.
This Privacy Statement explains what personal information we collect through our websites and online services, how we use that information, to whom we disclose it, and how we safeguard personal information. Unless indicated otherwise, this Policy applies only to personal information collected through the websites, microsites, mobile applications, and other online services of WOW KIREI and its subsidiaries that expressly adopt, display, or link to this Policy, and then only to the extent indicated (collectively, the “Services”).
This Privacy Statement governs Personal Information we collect from our customers and from our website, online services, apps and other online visitors (“you” or “your”), as well as information we automatically collect from your online visits (e.g. data collected via cookies).
For the purposes of this Privacy Statement, “Business Partner” means any subcontractor, vendor or other entity with whom we have an ongoing business relationship to provide products, services or information. “Personal Information” means information that may directly or indirectly identify you, such as your name, telephone number, email address, Internet Protocol (IP) address and location data.
| DATA CATEGORY | PURPOSE | SOURCES |
|---|---|---|
| Identifiers – e.g. name, email address, physical address, phone number, on line identifiers (such as username or social handle), etc. | We may use this data in order to identify you, deliver goods and services to you, market to you, personalize our goods and services to you, associate other data with you, analyse other data we collect, identify other potential customers (e.g. “look alike” customers), develop new goods and services, and for security and fraud prevention. | We obtain this data directly from you when you order goods or services and when you sign up for our services or marketing. We may also obtain your identifiers from affiliates (e.g. when you interact with their sites) and partners (e.g. to verify parts or all of your address). |
| Personal characteristics – e.g. clothing size, self-identified gender, age, etc. | We may use this data to personalize our goods and services to you, market to you, analyse other data we collect, identify other potential customers (e.g. determine how many customers are a certain size), and develop new goods and services. | We obtain this data directly from you when you order products and services (e.g. the size you select) and when you provide us that information (e.g. when you create an account). |
| Commercial information – e.g. payment information, purchasing history, product or service interests, product reviews, estimated income, etc. | We use this data to personalize our goods and services to you, market to you, analyse other data we collect, identify other potential customers (e.g. determine how many customers share product interests), and develop new goods and services. | We obtain this data from you when you order or browse products and services (e.g. purchase history) and when you provide us that information (e.g. product reviews). We may also obtain commercial information from affiliates (e.g. purchase history on their sites) and partners (e.g. estimated income). |
| Internet and network activity – e.g. IP address and location data, device ID, browse history, etc. | We may use this data in order to identify you, deliver goods and services to you, market to you, personalize our goods and services to you, associate other data with you, analyse other data we collect, identify other potential customers (e.g. “look alike” customers), develop new goods and services, and for security and fraud prevention. | We obtain this data directly when you interact with our websites, apps, etc. We may also obtain this information indirectly from cookies, tags and other digital tools, from affiliates (e.g. when you interact with their sites) and from partners |
| Images, audio, video, social media posts, etc. | We may use this data in marketing when you allow us to do so (e.g. post a review), to measure your engagement with our brands (e.g. social posts), to deliver you services, develop new goods and services, and for security and fraud prevention. | We obtain this data directly from you when you post to our websites, apps, or social channels, or tag us on social. We may also obtain this information when you participate in our recorded events. |
| Education, professional, or employment related information | We may use this data to market to you, personalize our goods and services to you, associate other data with you, analyse other data we collect, identify other potential customers, and develop new goods and services. | We obtain this data when you provide it to us. We may also obtain this information from affiliates and partners. |
| Communications with you, e.g. email, chat logs, etc. | We may use this data to provide you goods and services, develop new goods or services, market to you, and for security and fraud prevention. | We obtain this data when you communicate with us. |
| Analytic inferences drawn from other information | We may use analytics inferences drawn from other data to identify you, deliver goods and services to you, market to you, personalize our goods and services to you, associate other data with you, analyse other data we collect, identify other potential customers, develop new goods and services, and for security and fraud prevention. | We may make inferences drawn from other information based on our own observation, analysis or algorithms. We may also obtain inferences from our affiliates or from partners (e.g. credit score). |
We do not transfer your Personal Data to third parties in exchange for money and we will not do so. We may share your Personal Data with other WOW KIREI entities or Business Partners for the purposes described in this Privacy Statement, including (without limitation) to carry out transactions you request, or to make our business (or that of our subsidiaries) more responsive to your needs. Our subsidiaries and/or Business Partners may contact you with information about WOW KIREI branded products, services or offers. We will only share your Personal Data with WOW KIREI and Business Partners who agree to protect your Personal Data and use it solely for the purposes specified by WOW KIREI.
We will share your data with our subsidiaries, business partners and certain third parties and as necessary for legal requirements.
Subsidiaries: Are companies that are controlled by or are under common control with us.
Business Partners: They are partners who have agreed to use your data only for the purposes of providing the services in our contract and who have agreed not to “sell” your data. We may share your data with our Business Partners as described below:
Third Parties: They are unaffiliated companies that have not agreed to limit their use of data only to provide the services in our contract and/or have not agreed to “sell” your data. For example, they may need to use the data to provide you services directly that go beyond our contract with them (e.g. your credit card company). We share your data with “third parties” only as allowed by applicable law.
Identifiable Personal Data vs Non-Identifiable or Anonymised Data: We collect and maintain both identifiable personal and non-identifiable or anonymised data. Identifiable personal data is information that identifies you or could reasonably be associated with or linked to you. Non-Identifiable or anonymised information is data that is not linked and could not reasonably be linked to you.
The table show how we share your data:
| DATA CATEGORY | SHARED WITH BUSINESS PARTNERS | SHARED WITH 3RD PARTIES |
|---|---|---|
| Identifiers – e.g. name, email address, physical address, phone number, on line identifiers (such as username or social handle), etc. | We may share this data with business partners, such as logistics and fulfilment, electronic infrastructure, marketing and advertising, data analytics, and security providers. | We may share this data with third parties, including advertisers, marketing partners, and payment processors, networks and firms. |
| Personal characteristics – e.g. clothing size, self-identified gender, age, etc. | We may share this data with business partners, such as marketing and advertising, and data analytics providers. | We may share this data with third parties, including advertisers and marketing partners. |
| Commercial information – e.g. payment information, purchasing history, product or service interests, product reviews, estimated income, etc. | We may share this data with business partners, such as electronic infrastructure, marketing and advertising, data analytics, and security providers. | We may share this data with third parties, including advertisers, marketing partners, and payment processors, networks and firms. |
| Internet and network activity – e.g. IP address and location data, device ID, browse history, etc. | We may share this data with business partners, such as electronic infrastructure, marketing and advertising, data analytics, and security providers. | We may share this data with third parties, including advertisers, marketing partners, and payment processors, networks and firms. |
| Images, audio, video, social media posts, etc. | We may share this data with business partners such as electronic infrastructure, marketing and advertising, data analytics, and security providers. We may share this data publicly where you give us permission (e.g. reviews). | We may share this data with third parties, including advertisers and marketing partners. |
| Education, professional, or employment related information | We may share this data with business partners such as electronic infrastructure, marketing and advertising, data analytics, and security providers. | We may share this data with third parties, including advertisers, marketing partners. |
| Communications with you, e.g. email, chat logs, etc. | We may share this data with business partners such as logistics and fulfilment, electronic infrastructure, data analytics, and security providers. | |
| Inferences drawn from other information | We may share this data with business partners such as electronic infrastructure, data analytics, and security providers. | We may share this data with third parties, including advertisers, marketing partners. |
We may also disclose your Personal Data in connection with law enforcement, fraud prevention or other legal action; as required by law or regulation; if WOW KIREI (or a part of WOW KIREI) is sold or merges with another company; or if WOW KIREI reasonably believes it is necessary to protect WOW KIREI, its customers or the public.
We may disclose your Personal Data for any purpose with your consent.
Except as described above, we will not disclose your Personal Data to third parties for their own marketing purposes without your consent.
We use your personal data we obtain through the Services to:
- deliver our Services
- process your online orders;
- facilitate payment and transactions;
- create and manage your online account;
- personalize your online experience with content and offers that are tailored to your interests;
- provide customer service and respond to your inquiries and requests;
- include you in surveys and contests;
- enable you to post your content, such as comments, images or videos;
- facilitate networks of online social activity centred around our products and services;
- improve our Services, the manner in which offers are made on our Services, and the interactions and experience visitors have with our Services;
- enforce our website terms and conditions;
- prevent fraud and other prohibited or illegal activities;
- protect the security and integrity of our websites, our businesses and our products and services
- perform other functions or serve other purposes as disclosed to you at the point of collection, or as required or permitted by law
- enable you to interact with third-party content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment;
- market our products and services that may be of interest to you; and
- create aggregated, pseudonymized or anonymized information for statistical purposes.
Legal Basis for Processing Your Data
Our legal basis for collecting and using your Personal Data as described in this Privacy Statement will depend on the Personal Data concerned and the specific context in which we collect it. In general, we collect and process your Personal Data on one or more of the following bases:
| PURPOSE | PERSONAL DATA USED | LAWFUL BASIS |
|---|---|---|
| To carry out identity and credit checks | Contact details and payment information relating to you | We may have a legal obligation to undertake identification We also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid |
| To enter into and perform contracts where we may be supplying products/services to you | All the personal data we collect | To enter into and perform contracts with you We have a legitimate interest to properly perform contracts with third parties |
| To deal with queries, complaints, claims, legal disputes submitted by you and to make queries, complaints, claims, legal disputes in which relate to you | All the personal data we collect | This may be necessary to perform a contract with you We have a legitimate interest to improve the services and/or products we provide To defend, bring or establish legal claims |
| To maintain and improve our services and/or products | All the personal data we collect | We have a legitimate interest to improve the services and/or products we provide |
| Security of our IT systems | All the personal data we collect | We have a legitimate interest in ensuring the security of our IT systems |
| Direct Marketing | Contact details and services and products that we have determined may be of interest to you and/or which you have purchased in the past | We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively, if you have purchased similar services or products from us previously, we may market similar products or services as a legitimate interest in developing our business. You have the right to opt out from such marketing at any time. |
| To facilitate and communicate with you regarding our events and to provide you with an acceptable service | Your contact details, details of attendance, your comments in response forms and dietary requirements and CCTV images | We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We may also have a legal obligation to comply with health and safety requirements |
| For the prevention, detection or investigation of crime or the prosecution of offenders | All of the personal data we collect | We have a legitimate interest in protecting our rights and interests (for example in court cases) and in protecting the rights and interests of our employees, customers and any other third party with who we engage. To comply with any legal obligations and regulatory requirements |
| To comply with our legal and regulatory obligations | All of the personal data we collect | To comply with any legal obligations and regulatory requirements |
| To manage our relationship with you and to operate and manage our business and internal reporting | All of the personal data we collect | We have a legitimate interest to operate our business in an efficient way and to expand our business To enter into and perform contracts with yourself |
| Storage of records relating to you | All the personal data we collect | To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records |
| Marketing activities including our website, social media sites and Apps, and events | All the personal data we collect | We have a legitimate interest in tracking attendance at events and using the images and footage produced for business and marketing purposes We may also have a legal and/or regulatory obligation to comply with |
For some of your personal data you may have a legal, contractual or other requirement or obligation for you to provide us with your personal data. If you do not provide us with the requested personal data, we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate our relationship. For other personal data you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly provide you with our goods and services or perform our arrangements with you or the organisation you represent.
Where you have given us your consent to use your personal data in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us at [email protected]. We will generally only process your personal data based on your consent in relation to direct marketing or in relation to the processing of data relating to criminal convictions and offences.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal data to the extent that we are entitled to do so on a basis other than your consent. Withdrawing consent may also have the same effects as not providing the data in the first place, for example we may no longer be able to provide marketing information to you.
We may anonymise and aggregate any of the personal data we hold (so that it does not identify you). We may use anonymised and aggregated data for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services and for any other purpose.
Supplemental Privacy Notice for California Consumers
If you are a California resident you have certain rights, pursuant to the California Consumer Privacy Act of 2018 (CCPA). These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the below for a summary of your rights. You can exercise these rights using the contact details below.
- Right to Know: As a California resident, you have the right to request that we disclose what Personal Data we collect, use, disclose and/or sell.
- Right to Request Deletion: As a California resident, you have a right to request the deletion of your Personal Data collected or maintained by us.
- Right to Non-Discrimination: As a California resident, you have a right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights.
- Authorised Agent: As a California resident, you can exercise your CCPA rights or you can designate an authorised agent to make a request on your behalf. We may require that you provide the authorised agent written permission to submit a request on your behalf and that the authorised agent verifies their own identity directly with us.
- Contact us for more information: If you have questions about this Privacy Statement, including anything in this section about your CCPA rights, please contact us at [email protected]
You have the right to know whether your Personal Data is being sold. Your Personal Data is sold when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth within the CCPA.
We do not sell your Personal Data and have not sold your Personal Data in the preceding 12 months. For this reason, we have not included an opt-out of sale of your Personal Data.
To submit a verifiable consumer request, you or your authorized agent can do so by sending a written request to [email protected].
You may only make a verifiable consumer request to us twice within a 12-month period. We may ask for certain information to verify the request in accordance with applicable law. The verifiable consumer request to know and request for deletion must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Supplemental Privacy Notice for EU Citizens
Where the processing of your Personal Data is subject to EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law:
- Access: you have the right to request information about how we process your Personal Data and to obtain a copy of that Personal Data
- Rectification: you have the right to request the rectification of inaccurate Personal Data about you and for any incomplete Personal Data about you to be completed
- Objection: you have the right to object to the processing of your Personal Data which is based on our legitimate interests (as described above)
- Erasure: you have the right to request the erasure of your Personal Data (subject to certain conditions)
- Automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
- Restriction: you have the right to ask us to restrict our processing of your Personal Data, so that we no longer process that information until the restriction is lifted
- Portability: you have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organisation in certain circumstances.
In addition to the above, you have the right to lodge a complaint with a supervisory authority (such as the supervisory authority in your member state of habitual residence, place of work or where the alleged infringement took place) if you consider that our processing of your Personal Data infringes applicable data protection law.
If you have any questions about the type of Personal Data we hold about you or if you wish to request deletion or correction of Personal Data we hold about you, or exercise any other data subject right, please send a written request to [email protected] or to the postal address provided at the bottom of this Privacy Statement. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.
You have the right to opt out of receiving marketing communications from us at any time, by:
- informing us that you wish to change your marketing preferences by contacting our customer support team at [email protected];
- making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or
- contacting us via email at [email protected];
Any marketing by WOW KIREI, or any third parties on behalf of WOW KIREI, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences (including the possibility of being removed from our advertising and marketing lists as set out above).
Please allow up to 10 business days for your email preferences to take effect. As some promotions are developed in advance, you may sometimes receive marketing communications after we receive your preference request.
If you opt out of receiving marketing communications, we may still communicate with you in connection with order updates and other non-marketing communications.
WOW KIREI takes all reasonable steps to protect your Personal Data from misuse, interference and loss, as well as unauthorised access, modification or disclosure. The ways we do this include:
- using encryption when collecting or transferring sensitive data
- having in place technical and organisational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services;
- weekly penetration testing of all systems;
- limiting physical access to our premises;
- limiting access to the data we collect about you;
- ensuring that we and our Business Partners have appropriate security safeguards to keep Personal Data secure; and
- where required by law, destroying or de-identifying Personal Data.
We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from WOW KIREI asking for your personal data. WOW KIREI will not request your ID or password through email.
We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Statement and in accordance with our retention policies and applicable law.
WOW KIREI may transfer your Personal Data to subsidiaries and/or to its Business Partners, if required for the purposes described in this Privacy Statement. This may involve the transfer of your Personal Data to countries outside your home country or region, including outside the European Economic Area if that is your region, which may have a different level of data protection from your home country. Such countries may include, without limitation, countries in which WOW KIREI or its subsidiaries, affiliates or Business Partners maintain facilities (see the bottom of this Privacy Statement for a list of our affiliates). In order to provide adequate protection for the transfer of your Personal Data, we have in place contractual arrangements (as appropriate) with our subsidiaries, affiliates and Business Partners in respect of such transfers (based on EU Commission approved standard contractual clauses). We will take all reasonable technical and organisational measures to safeguard Personal Data we transfer.
WOW KIREI takes children’s privacy seriously. We do not knowingly collect personal data from children under the age of 16 through our websites. If you are under 16 years of age, please do not submit any Personal Data through our websites without the express consent and participation of a parent or guardian.
How We and Our Partners Use Cookies
WOW KIREI websites use WOW KIREI and third-party “cookies” to enable you to use our websites and associated services and to help personalise your online experience. These technologies and the data collected about you may be used to track your activity across multiple devices. Where appropriate, we use cookies to store your preferences and other data on your computer in order to save you time by eliminating the need to enter the same data repeatedly.
A cookie is a piece of text that is placed on your computer’s hard drive. Depending on the settings you have selected, your browser adds the text to your device as a small file. Many browsers are set to accept cookies by default. You have the ability to accept or decline cookies as you prefer. The Help portion of your web browser, most likely found on the toolbar, typically tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
Cookies allow you to take advantage of some of our website’s essential features. If you choose to decline cookies, you may not be able to sign in or use other interactive features of WOW KIREI websites and services that depend on cookies.
Targeted Display Advertising by WOW KIREI and Others
WOW KIREI also works with advertising and personalisation Business Partners to use cookies, and Internet browsing to help us display personalised content and appropriate advertising during your visits to mobile applications, wowkirei.com and other websites. Cookies placed by these Business Partners also assist us with measuring the performance of our advertising campaigns and with identifying the pages you view, the links and ads you click on, other actions you take on those web pages, and the site from which you came before arriving at a web page. These cookies can be effective whether you are on wowkirei.com or another website. If you opt out of receiving targeted display advertising, the data associated with these cookies will not be used.
“Do Not Track” Signals
Please note that while you may be able to control the use of cookies through your web browser as described in the “How We and Our Partners Use Cookies” section above, some web browsers may also give you the ability to enable a “do not track” setting. This setting sends a special signal to the websites you encounter while web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. WOW KIREI does not respond to web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Statement. For more information about do not track,” visit www.allaboutdnt.org.
Targeted Email Marketing by WOW KIREI
Some marketing you receive, including email marketing, may also be personalised based on your visits to wowkirei.com and your browsing history. In addition, when you click on some links in email marketing you receive, our email service provider may place a cookie on your browser. This type of cookie would be linked to your email address or IP address and used to gather data about the products and services you view and access on wowkirei.com. Data gathered may be used to personalise and customise future email marketing messages you receive. You may opt out of this use by clicking on the unsubscribe link provided in every personalised email marketing message you receive.
How We and Our Partners Use Web Beacons, Pixel Tags and Tracking Technology
WOW KIREI or its Business Partners may use web beacons on our websites, in our email messages, in our advertisements on other websites, or in our advertisements in others’ email messages.
A web beacon is an electronic image that can be used to recognise a cookie on your computer when you view a web page or email message. Web beacons help us measure the effectiveness of our website and our advertising in various ways. For example, web beacons may count the number of individuals who visit our website from a particular advertisement or they may tell us when a web page is viewed and provide a description of the page where the web beacon is placed. Web beacons may also measure the effectiveness of our email campaigns, by counting the number of individuals who open or act upon an email message, determining when an email message is opened and determining how many times an email message is forwarded. Subject to local laws, we may combine the data that we collect through web beacons with other Personal Data we have collected from you.
We may allow some of our Business Partners to compile individual or aggregated statistics from the use of web beacons on wowkirei.com by WOW KIREI, its agents or others, to determine the effectiveness of online marketing and to develop statistics on how often clicking on an advertisement results in an action on the advertiser’s site. Aggregate data may include demographic and usage data. No Personal Data about you is shared with Business Partners for this research.
You can make some web beacons unusable by rejecting cookies in your web browser as described in the How We and Our Partners Use Cookies section above.
When you visit our websites or view one of our email messages, we may use pixel tags (also called “clear” gifs), tracking links and/or similar technology to note some of the pages you visit on our websites. We may also use pixel tags to determine what types of email your browser supports. We may use the data collected through web beacons, pixel tags, tracking links and similar technology in combination with your Personal Data to personalise your experience on wowkirei.com and to provide you with more useful and relevant advertisements.
Social Media Features
Our website includes social media features, including Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing them.
Please be aware that WOW KIREI provides links to other websites, which if you click on them may collect Personal Data about you. The data practices of those third-party websites linked to wowkirei.com are not covered by this Privacy Statement.
We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Data, we will revise this Privacy Statement to reflect such changes and revise this Privacy Statement’s effective date, included at the end of this section. We encourage you to periodically review this Privacy Statement to be informed of how we are using and protecting your Personal Data.
If you would like to contact us for any reason regarding our privacy practices, please email us at [email protected] or write to us at the following address:
Wow Kirei Limited Liability Co.
30 N Gould Street, STE 4000
Sheridan, WY
82801
USA
Contact Information for our Data Protection Officer:
J.Huang, Chief Privacy Officer
[email protected]
For data subjects located in the EU:
Wow Kirei Limited Liability Co. is the controller of your Personal Data (unless otherwise stated)
For the purposes of the EU General Data Protection Regulation, Wow Kirei Limited Liability Co.has appointed Logic Bounce Europe Ltd. to be its representative in the EU. Logic Bounce Europe Limited can be contacted as follows:
Attn: Privacy/Legal Department
Wow Kirei c/o Logic Bounce Europe Ltd.
5 School House Lane East
Dublin 2
D02 EC64
Ireland
Email: [email protected]
Effective Date: January 1 2021.
Version: 1.02
*Wow Kirei Subsidiaries: Wow Kirei Limited Liability Co.