Kaizen Lab Europe Limited DOES NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE.
This policy applies to Kaizen Lab Europe Limited collection, use, storage and disclosure of information by Kaizen Lab Europe Limited on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various third party websites, and (c) to Kaizen Lab Europe Limited other information collection, including the purchase of customer lists from third parties. Kaizen Lab Europe Limited is not responsible for the information collection or privacy practices of third web sites or applications.
1. COLLECTION OF INFORMATION.
1.1 SURVEY INFORMATION.
Kaizen Lab Europe Limited collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a Kaizen Lab Europe Limited survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, Kaizen Lab Europe Limited or a third party (a “Third Party”) may ask an individual to provide various information to Kaizen Lab Europe Limited, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). Kaizen Lab Europe Limited may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to Kaizen Lab Europe Limited or Third Party, but an individual may receive incentives from Kaizen Lab Europe Limited or a Third Party in exchange for providing Survey Information to Kaizen Lab Europe Limited.
1.2 THIRD PARTY LIST INFORMATION.
Kaizen Lab Europe Limited collects information from individuals when an individual provides information to a third party and Kaizen Lab Europe Limited subsequently purchases, licenses, or otherwise acquires the information from the third party (the “Seller”). Such purchased information may include, but is not limited to, an individual’s name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, credit card information, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, Kaizen Lab Europe Limited seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to Kaizen Lab Europe Limited and that the Seller has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller’s list.
1.3 OTHER INFORMATIONS.
Other occasions when Kaizen Lab Europe Limited obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Kaizen Lab Europe Limited or by a third party, (2) when an individual requests assistance through Kaizen Lab Europe Limited’s customer service department, and (3) when an individual voluntarily subscribes to a Kaizen Lab Europe Limited service or newsletter (together, “Other Information”).
1.4 COOKIES, WEB BEACONS, AND OTHER INFO COLLECTED USING TECHNOLOGY.
Kaizen Lab Europe Limited currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, Kaizen Lab Europe Limited may use other new and evolving sources of information in the future (together, “Technology Information”).
A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows Kaizen Lab Europe Limited to identify the individual with his or her corresponding data that resides in Kaizen Lab Europe Limited database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites
(B) WEB BEACONS.
A web beacon is programming code that can be used to display an image on a web page (by using an programming function — see http://truste.org for more information), but can also be used to transfer an individual’s unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows Kaizen Lab Europe Limited to track certain web sites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, Kaizen Lab Europe Limited might place, with the consent of a third party website, a web beacon on the third party’s website where fishing products are sold. When Bill, an individual listed in Kaizen Lab Europe Limited’s database, visits the fishing website, Kaizen Lab Europe Limited receives notice by means of the web beacon that Bill visited the fishing site, and Kaizen Lab Europe Limited would then update Bill’s profile with the information that Bill is interested in fishing. Kaizen Lab Europe Limited may thereafter present offers of fishing related products and services to Bill. In addition to using web beacons on web pages, Kaizen Lab Europe Limited also uses web beacons in email messages sent to individuals listed in Kaizen Lab Europe Limited’s database.
(C) NEW TECHNOLOGY.
The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is Kaizen Lab Europe Limited use of new and evolving technology. As a result, Kaizen Lab Europe Limited strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
1.5 OUTSIDE INFORMATION.
Kaizen Lab Europe Limited may receive information about individuals from third parties or from other sources of information outside of Kaizen Lab Europe Limited including information located in public databases (“Outside Information”).
1.6 INDIVIDUAL INFORMATION
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information Kaizen Lab Europe Limited gathers or receives about individuals
1.7 NO INFORMATION COLLECTED FROM CHILDREN.
Kaizen Lab Europe Limited will never knowingly collect any personal information about children under the age of 13. If Kaizen Lab Europe Limited obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, Kaizen Lab Europe Limited has no such information to use or to disclose to third parties. Kaizen Lab Europe Limited has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
1.8 CREDIT CARD INFORMATION
Kaizen Lab Europe Limited may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when an individual places an order from Kaizen Lab Europe Limited. When the Credit Card Information is submitted to Kaizen Lab Europe Limited, such information is encrypted and is protected with SSL encryption software. Kaizen Lab Europe Limited will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.
2. USE OF INDIVIDUAL INFORMATION
2.1 DISCRETION TO USE INFORMATION.
Kaizen Lab Europe Limited MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION. The following paragraphs in Section 2 describe how Kaizen Lab Europe Limited currently uses Individual Information, but Kaizen Lab Europe Limited may change or broaden its use at any time. As noted below, Kaizen Lab Europe Limited may update this policy from time to time. Kaizen Lab Europe Limited may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties, please inform us by contacting customer service at 1.800.432.9l30 and we will certainly honor your request.
Kaizen Lab Europe Limited uses Individual Information to provide promotional offers by email to individuals. Kaizen Lab Europe Limited may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list.
2.2(A) CONTENT OF EMAIL MESSAGES.
In certain commercial email messages sent by Kaizen Lab Europe Limited, an advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to Kaizen Lab Europe Limited. The “Subject:” line of Kaizen Lab Europe Limited email messages will usually contain a line provided from the advertiser to Kaizen Lab Europe Limited.
2.2(B) SOLICITED EMAIL.
Kaizen Lab Europe Limited only sends email to individuals who have agreed on the Websites to receive email from Kaizen Lab Europe Limited or to individuals who have agreed on third party websites to receive email from third parties such as Kaizen Lab Europe Limited. Kaizen Lab Europe Limited does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Kaizen Lab Europe Limited email messages.
2.3 TARGETED ADVERTISING.
Kaizen Lab Europe Limited uses Individual Information to target advertising to an individual. When an individual is using the Internet, Kaizen Lab Europe Limited uses Technology Information (see also Section 2.5 below) to associate an individual with that person’s Individual Information, and Kaizen Lab Europe Limited attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. Kaizen Lab Europe Limited may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
2.4 DIRECT MAIL AND TELEMARKETING.
Kaizen Lab Europe Limited uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
2.5 USE OF TECHNOLOGY INFORMATION.
Kaizen Lab Europe Limited uses Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of Kaizen Lab Europe Limited web sites are most frequently visited. This information helps Kaizen Lab Europe Limited to better understand the online habits of individuals so that Kaizen Lab Europe Limited can target advertising and promotions to them.
2.6 PROFILES OF INDIVIDUALS.
Kaizen Lab Europe Limited uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.
2.7 STORAGE OF INDIVIDUAL INFORMATION.
Kaizen Lab Europe Limited stores the Individual Information in a database on Kaizen Lab Europe Limited computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Kaizen Lab Europe Limited control. Not withstanding such measures, Kaizen Lab Europe Limited cannot guarantee that its security measures will prevent Kaizen Lab Europe Limited computers from being illegally accessed, and the Individual Information on them stolen or altered.
3. DISSEMINATION OF INDIVIDUAL INFORMATION.
3.1 SALE OR TRANSFER TO THIRD PARTIES.
Kaizen Lab Europe Limited MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN Kaizen Lab Europe Limited SOLE DISCRETION. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties, please inform us by contacting customer service at 1.800.432.9l30 and we will
3.2 ORDER FULFILLMENT.
Kaizen Lab Europe Limited will transfer Individual Information to third parties when necessary to provide a product or service that a person orders from such third party while using Kaizen Lab Europe Limited web sites or when responding to offers provided by Kaizen Lab Europe Limited.
3.3 LEGAL PROCESS.
Kaizen Lab Europe Limited may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.4 SUMMARY DATA.
Kaizen Lab Europe Limited may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting customer service at the number on the order page. Kaizen Lab Europe Limited may also grant advertising clients and email services providers’ access to an individual’s email address to verify the origin of the Individual Information collected.
4. PRIVACY PRACTICES OF THIRD PARTIES.
4.1 ADVERTISER COOKIES AND WEB BEACONS.
Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. Kaizen Lab Europe Limited does not control Advertisers’ use of such technology and Kaizen Lab Europe Limited has no responsibility for the use of such technology to gather information about individuals.
The Websites and email messages sometimes contain hypertext links to the web sites of third parties. Kaizen Lab Europe Limited is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. Kaizen Lab Europe Limited does not operate or control in any respect any information, software, products or services available on such third party web sites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
4.3 AFFILIATED COMPANIES.
Kaizen Lab Europe Limited may disclose, transfer, and sell Individual Information to entities affiliated with Kaizen Lab Europe Limited in Kaizen Lab Europe Limited discretion.
4.4 BUSINESS TRANSFERS.
As we continue to develop our business, we might sell or buy stores, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise).
5. UNSUBSCRIBE PROCEDURES.
If you wish to discontinue receiving email messages from Kaizen Lab Europe Limited please write to:
Kaizen Lab Europe Limited
Attn: email unsubscribe
LOWER GROUND FLOOR
64 LOWER MOUNT STREET
send an unsubscribe message to email@example.com
We reserve the right to add Individual Information to multiple lists maintained by Kaizen Lab Europe Limited. For more information about protecting your privacy, you may wish to visit: www.ftc.gov.
LAST UPDATED ON FEBRUARY, 2019 © KAIZEN LAB EUROPE LIMITED