COLGATE-PALMOLIVE COMPANY GLOBAL PRIVACY POLICY
Last Updated: January 2024
Colgate-Palmolive Company and its subsidiaries and affiliates (“Colgate” or “we” or “our” or “us”) respect your privacy and value the relationship we have with you. Therefore, we handle your personal data responsibly, and we want you to be familiar with how we collect, use, disclose, and protect your data. This Privacy Policy describes our practices in connection with your data and your related rights.
This Privacy Policy also describes our practices in connection with data that we collect about professionals such as dental professionals, estheticians, veterinary professionals and students, and health care experts (“Professionals”), in order to provide them with professionally-oriented services (“Professional Services”).
In this Privacy Policy, we refer to our Websites, Apps, Devices, Social Media Pages, email messages, advertisements, product recommendations, offline activities and Professional Services collectively as the “Services.” We may provide additional notices in connection with certain Services or offerings.
WHAT IS PERSONAL DATA?
Personal Data is data that identifies, describes, or is reasonably capable of being associated with or linked with you. This includes information like name and email address, and can also include other identifiers as explained below.
CONNECTED DEVICES
We also collect, use, and disclose Personal Data in connection with our Connected Health Devices, including the hum by Colgate and Colgate Connect E1 Smart Toothbrush and Colgate Whitening LED kit (the “Devices”) in several ways:
The technology used to evaluate your tooth brushing, which includes algorithms that analyze your face and your brushing technique, is run in real time on your device (and thus is not collected or captured by Colgate). We do not collect this information from your device or access it on your device, nor do we use this technology to identify you.
We use Personal Data to provide the Services’ functionality to you, such as, if you use our Apps, providing you with a weekly review of your activity, to better understand you and provide content, information, and offers tailored to your interests, and to analyze use of the Services so that we can improve them. For more information on how we use Personal Data, please see below.
HOW WE USE PERSONAL DATA
We and authorized third-party service providers working on our behalf use Personal Data for legitimate business purposes when we interact with consumers, the public, Professionals, and our retail customers. Below we provide an overview of our uses of Personal Data.
INTERACTING WITH CONSUMERS AND THE PUBLIC
INTERACTING WITH PROFESSIONALS, RETAIL CUSTOMERS, AND BUSINESS PARTNERS
Information we collect from Professionals, Retail Customers, Business Partners includes preferred language; professional biography and education; webstore account number and ID; data regarding your licensures, specialties, affiliations, publications, credentials, and other achievements; and data regarding your use and purchase of our products, including credit card information as applicable, your interactions with us, and services for those to whom you provide care. Below we provide an overview of our uses of Professionals’ Personal Data.
OTHER USES AND DISCLOSURES
These uses and disclosures of your personal data can occur outside your country of residence.
We engage in these activities and process your Personal Data to manage our relationship with you, comply with a legal obligation, or provide you with Services / perform a contract with you, where the processing occurs with your consent, or is in our legitimate interest and not overridden by your data protection interests or fundamental rights.
Colgate does not sell or exchange your Personal Data for monetary compensation. See section below on “Your Choices Regarding Disclosure of Personal Data” for more information about how Colgate may disclose your Personal Data to third parties and the choices you have to restrict or stop such disclosure.
Incentives for Personal Data
We may offer programs with financial incentives or service differences such as a bonus card, discount or a coupon to consumers or Professionals in exchange for their Personal Data. We may collect Personal Data such as your name, email address, preferences, experiences, and engagement with Colgate (“Consumer Data”). If you participate in those programs, we will obtain your consent, which can be revoked at any time. Please note revocation of consent may affect your eligibility to participate in those programs. We estimate that the value of the Consumer Data is the value of the benefit we offer to you in connection with the promotion or survey, which is reasonably related to the costs associated with offering such benefit.
HOW WE DISCLOSE PERSONAL DATA
YOUR CHOICES REGARDING DISCLOSURE OF PERSONAL DATA
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. Residents of certain U.S. states, particularly California, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia may have additional rights as described in the section “California and Other State Privacy Rights” below.
You may opt-out from:
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails, texts or SMS messages from us, you may opt-out by following the instructions contained in each such message or by contacting Consumer Affairs.
- Receiving push notifications from us: If you no longer want to receive push notifications, you may stop these notifications through your device settings.
- Receiving marketing communications related to our Professional Services: If you use our Professional Services and no longer want to receive marketing communications from us, you may opt-out by contacting Consumer Affairs. In your request, please provide your name and address where you no longer wish to be contacted.
- Our sharing of your Personal Data with subsidiaries or affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Data on a going-forward basis with our subsidiaries or affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting Consumer Affairs.
- Our sharing of your Personal Data with unaffiliated third parties for their direct marketing or analytical purposes: If you would prefer that we discontinue sharing your Personal Data on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by contacting Consumer Affairs.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important administrative or transactional messages as applicable, from which you cannot opt out.
HOW WE PROTECT YOUR PERSONAL DATA
We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization and endeavor to prevent unauthorized access. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting Consumer Affairs.
HOW LONG WE RETAIN YOUR DATA
We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law and Company policy.
The criteria used to determine our retention periods include:
- The length of time we provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- The length of time we have an ongoing relationship with you;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, government investigations or regulatory considerations).
SENSITIVE PERSONAL DATA
Unless we specifically request it in connection with the Services, we ask that you not send us, and you not disclose, any Sensitive Personal Data (e.g., social security numbers, data related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
MINORS / CHILDREN’S PRIVACY - NOTE TO PARENTS AND CAREGIVERS
Unless otherwise indicated, the Services are not directed to minors as defined by applicable law. For example, in the US, minors are individuals under the age of 13, and in the EEA, we honor Member State laws, and we do not knowingly collect Personal Data from minors. If you provide us with Personal Data of minors, you represent that you have the appropriate authority to do so and that you can demonstrate such authority to us upon request. We do not have actual knowledge about selling or sharing Personal Data of consumers under the age of 16.
We care about the privacy of children. We recognize that children’s use of the Internet and email raises special concerns regarding the privacy and security of Personal Data. We encourage all parents and caregivers to check and monitor their children’s online activities.
Your child can enjoy most of the content and activities in our children’s areas without providing any Personal Data to us. For example, https://www.colgate.com/en-us/products/kids provides information about Colgate kids’ products, as well as educational videos that help kids to develop healthy habits. In addition, https://www.colgate.com/en-us/bright-smiles-bright-futures provides oral educational materials designed for teachers, parents and kids, and has fun activities for kids.
For your child’s enjoyment, we may link to other sites. We are not responsible for those other sites, and we advise you to check the privacy policies on those sites as well.
We sometimes solicit or accept submissions from children, such as artwork entered in a contest, some of which may be posted on our sites. Such submissions may be made offline as well as online. If a child or parent wants us to post a photograph or any other Personal Data of a child, we require a signed parental permission and release form. When children make submissions to us offline, such as by regular mail, we may retain all of the information they submit to us. Unless we receive a signed parental permission form, we screen all offline submissions before they are posted, and strip out and delete any Personal Data they may contain prior to posting them.
In the limited instances where we collect Personal Data from children with a signed parental permission and release form, applicable law may give parents the right to review, correct, update, suppress, restrict and/or delete Personal Data we have collected from their children, or to refuse to permit further collection, use or disclosure of such Personal Data. If you would like to exercise any of these rights, please Contact Us.
THIRD PARTY SERVICES
We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Data will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Data.
This Privacy Policy does not address, and we are not responsible for, the privacy, data, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our subsidiaries or affiliates.
In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
CALIFORNIA AND OTHER STATE PRIVACY RIGHTS
If you are a resident of California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, the law in your state provides you with certain rights with respect to your Personal Data which may include:
- The right to know what, if any, Personal Data we have collected, used, disclosed, and sold about you, including the categories of Personal Data, the categories of sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom Colgate discloses Personal Data, and the specific pieces of Personal Data Colgate has collected about you.
- The right to obtain a copy of Personal Data we have about you in a portable and, to the extent technically feasible, readily usable format.
- The right to correct inaccurate personal information about you , taking into account the nature of the Personal Data and the purposes of the processing.
- The right to request deletion of certain Personal Data.
- The right to opt-out of the selling of your Personal Data , which you can exercise at our website by clicking here.
- The right to opt-out of the sharing of your Personal Data for purposes of targeted advertising which you can exercise at our website here or by modifying your privacy preferences (e.g., Global Privacy Control), available through certain internet browsers and extensions, that signal your preference to opt out. Please note that clearing your cookies at any time will remove the signal of your selected privacy preferences.
- The right to limit the use of your Sensitive Personal Data , which you can exercise through the Contact Us form available on our website.
- If we deny your request, the right to appeal our decision.
California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, we disclosed certain personal information to authorized third parties to receive services, insights, or other valuable consideration.
Categories of Personal Information
Categories of third parties with whom we disclose personal information for business or other permitted purposes as applicable:
Identifiers:
- Subsidiaries
- Service Providers
Internet / Network Activity
- Subsidiaries
- Service Providers
Commercial and Payment Information
- Service Providers
- Retail Customers / Business Partners
Location Data
- Service Providers
User Generated Content
- Subsidiaries
- Service Providers
- Retail Customers / Business Partners
Audio / Visual Information
- Subsidiaries
- Service Providers
- Retail Customers / Business Partners
Demographics
- Subsidiaries
- Service Providers
- Retail Customers / Business Partners
Physical Characteristics
- Service Providers
Health Information
- Subsidiaries in the event of an adverse event
Inferences
- Subsidiaries
- Service Providers
- Retail Customers / Business Partners
Sensitive Personal Information
- Service Providers
Colgate does not use or disclose Sensitive Personal Data, as defined in applicable laws, for any purposes other than those permitted by applicable law.
This Privacy Policy describes how we may share your information for marketing purposes, as described above. If you are a California resident, the Shine the Light law permits you to request and obtain from us once per calendar year information about any of your Personal Data shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us through the Contact Us form on our website.
Submitting Requests
If you are a resident of California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, subject to the applicable local law in your state, you may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Data we have collected about you by accessing our Consumer Affairs page by clicking here or by contacting our Toll-Free Telephone Number at 1-800-468-6502.
We will respond to your request in compliance with the requirements of your state’s applicable laws. Please note that we are only required to honor California requests to know twice in a 12-month period.
Verification of Your Identity
When you exercise these rights and submit a request to us, we will verify your identity by asking you to provide us with additional information such as your email address, or order numbers of previous orders of our products and services. We also may use a third-party verification provider to verify your identity.
Appeal
Residents of Colorado, Connecticut, Oregon, Texas and Virginia may appeal a decision we have made regarding their requests by calling us at 1-800-468-6502 or by using the form available on our website. We will respond to appeals from Virginia and Connecticut residents within 60 days. We will respond to appeals from Colorado residents within 45 days.
Non-Discrimination
If you make a request under the applicable California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia data privacy laws, we will not discriminate against you in any way. For example, we will not deny you discounts or other benefits or impose penalties on you, or provide you with or suggest that you will receive a different level or quality of benefits or services.
Automated Decision-Making
We generally do not use automated decision-making technology, as that term is defined by state privacy laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.
Authorized Agents
You may permit an authorized agent to submit a request to know or to delete your Personal Data. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Data.
JURISDICTION AND CROSS BORDER TRANSFER
Given that we operate internationally, our processing of your Personal Data may involve the international transfer of your Personal Data. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your Personal Data will be transferred to countries outside of your country of residence, to businesses in countries which may have data protection rules that are different from and not equivalent to those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data. By using the Services and providing your Personal Data, you acknowledge that the Services are subject to the laws of the United States, and consent to the processing of your Personal Data in the United States.
COUNTRY-SPECIFIC PRIVACY RIGHTS
For individuals residing outside of the United States, the law in your jurisdiction may provide you with certain rights with respect to your Personal Data which may include:
- The right to be informed about how we use your Personal Data
- The right of access to the Personal Data we have about you
- The right to deletion / erasure / be forgotten
- The right to correction / rectification
- The right to withdraw consent at any time for processing of Personal Data based on consent
- The right to object to processing of Personal Data based on legitimate interests
- The right to restrict the processing of your Personal Data
- The right to opt out of the sharing of your Personal Data with third parties including managing / rejecting cookies and other tracking technologies
- The right to data portability
- The right to lodge a complaint with the data protection / supervisory authority
Please see below for more information on exercising your data privacy rights.
THE EEA
If you reside in the EEA, you may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law has occurred. A list of data protection authorities is available here.
Regarding jurisdiction and cross-border transfers, some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You may obtain a copy of these measures by clicking here.
AUSTRALIA
If you reside in Australia, this section applies.
To the extent that the Australian Privacy Act 1988 (Cth) applies to Colgate entities, such entities will comply with the requirements for controllers as specified in the Act. Click here to identify the controller responsible for collection, use, and disclosure of your Personal Data under this Privacy Policy.
You can access, update and correct personal information we hold about you through a Personal Information Handling Form which you can request by contacting:
The Privacy Officer
Level 29
420 George St
Sydney NSW 2000, Australia
Email: PrivacyOfficer_Australia@colpal.com
If we are unable to fulfill your request, we will notify you in writing. Even if you do not submit a request, if we have reason to believe that Personal Data we hold about you is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct or otherwise adjust our processing of that information.
MAINLAND CHINA
If you reside in Mainland China (excluding the Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan region), this section applies. This section also applies to Colgate-Palmolive (China) Co., Ltd. and its affiliates in the collection of personal information through various channels, both online and offline, within Mainland China (excluding the Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan region). In the event of any inconsistency between the content of this section and Colgate-Palmolive Company Global Privacy Policy, this section shall prevail.
Privacy Rights
The rights you have and the ways to exercise them are as follows:
- The right to know the basic and extended business functions of the services or products we provide, the specific personal information collected for each function and their purposes. In specific circumstances (such as when using an app or mini-program), the right to know the necessary permissions required for collecting personal information, as well as the right to know the types or names of the SDKs we embed and the purposes, types, and methods of personal information collection. Detailed disclosures of this information will be provided in the privacy policy of the specific services or products we offer to you, as necessary. Where applicable, please review such policy when using the services or products;
- The right to request access to, copy, correct, supplement, or delete certain personal information;
- The right to opt-out of personalized advertising recommendation services;
- The right to withdraw consent;
- The right to deactivate your account where applicable; and
- The right to request an explanation of how specific products or services process your personal information.
You can exercise the aforesaid rights by contacting Consumer Affairs or through specific methods provided to you when you agreed to our collection of your personal information in specific scenarios.
Cross-Border Transfers
In principle, we will store domestically the personal information collected and generated during our operations within Mainland China. We will only provide your personal information overseas for the purpose of fulfilling the contract with you or other lawful processing reasons. In such cases, we will inform you of the name, contact details, processing purposes, methods of processing, types of personal information, and the ways and procedures for you to exercise your rights with the overseas recipient, in accordance with the requirements of Chinese law, and obtain your separate consent, as well as fulfill other compliance obligations we should undertake.
How We Protect Your Personal Information
We have implemented industry-standard, reasonably feasible security measures to protect your information and prevent unauthorized access, public disclosure, use, modification, damage, or loss of personal information. For example, [we use encryption technology to enhance the security of personal information; data exchanged between your browser and our server is protected by SSL protocol encryption; we provide HTTPS protocol for secure browsing; we use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to ensure that only authorized personnel can access personal information. We conduct information security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information. We have established an advanced data security management system in the industry, enhancing the security of personal information from the dimensions of organizational construction, system design, personnel management, and product technology.]
Updates to our Privacy Policy
To provide you with better services, our Privacy Policy will be updated in a timely manner as our business develops. Without your explicit consent, we will not reduce the rights you should enjoy under this Privacy Policy. We will issue updated versions and post any changes to this policy on our Website as they take effect or remind you of updates to the content in other appropriate ways. Please also visit Colgate's official website, App, and other product or service portals to stay informed about the latest Privacy Policy. If there are significant changes to this Privacy Policy, we will also provide more noticeable notifications, such as using pop-up windows, text messages, or emailing you directly.
Emergency Response Plan
To address the potential risks of personal information leakage, destruction, and loss, we have established a dedicated emergency response team. According to the company's security event handling standards, we initiate security plans for different security events to stop losses, analyze, develop remedial measures, and work with relevant departments for tracing and crackdown. We will also inform you in a timely manner according to the requirements of laws and regulations: the basic situation and possible impact of the security event, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly notify you of the relevant situation of the event by email, letter, phone, push notification, etc. If it is difficult to notify each subject of personal information individually, we will take reasonable and effective measures to make announcements. At the same time, we will also proactively report the handling of personal information security events to the regulatory authorities as required.
Contact Us
We have dedicated personnel to be responsible for the security of your personal information. If you have any questions about this Privacy Policy or any complaints or comments about the processing of your personal information, you can contact us through Consumer Affairs. We will complete identity verification and respond within fifteen (15) business days. You can also file complaints and reports against illegal personal information processing activities to the departments of the People's Republic of China (excluding the Hong Kong Special Administrative Region, Macao Special Administrative Region, and Taiwan region) responsible for personal information protection.
JAPAN
If you reside in Japan, this section applies.
Definitions of terms in this Privacy Policy are subject to the following:
“Personal Data” includes “Personal Information” defined by the Act on the Protection of Personal Information (Act No. 57 of 2003) , which can be used to identify an individual by itself or by easy cross-checking with other information but does not necessarily have to constitute a database or equivalent.
“Sensitive Personal Data” and “Sensitive Personal Information” mean personal information as to an identifiable person's race, creed, social status, medical history, criminal record, the fact of having suffered damage by a crime, or other identifiers or their equivalent prescribed by Cabinet Order as those of requiring special care so as not to cause unjust discrimination, prejudice or other disadvantages to that person.
Sharing Personal Data
Joint use
As mentioned in “HOW WE DISCLOSE PERSONAL DATA”, we jointly use your Personal Data with our subsidiaries, affiliates, and brands for the purposes described in “HOW WE USE PERSONAL DATA” in this Privacy Policy. The categories of Jointly used Personal Data is also described in “WHAT PERSONAL DATA WE COLLECT” in this Privacy Policy. The person responsible for this joint use is Hill’s-Colgate (Japan) Ltd. For more information on joint use, please contact us here.
Outsourcing
We may outsource all or part of the processing of Personal Data to third-party service providers or other third parties. In such cases, we will provide necessary and appropriate supervision of these third parties by, for example, concluding contracts regarding the processing of Personal Data with them to ensure the Personal Data is securely managed.
Cross-Border Transfer
Your Personal Data may be transferred outside Japan. Even in countries that are not recognized by the Japanese data protection authority, Personal Information Protection Commission (“PPC”), as having a protection regime equivalent to that of Japan, recipients can be assured that your Personal Data will be protected by common rules within the group, including us, or by individual contracts.
For more information on cross border transfer, please contact us here.
Supervisory authority
You may lodge a complaint with the PPC.
NEW ZEALAND
If you reside in New Zealand, this section applies.
We will collect, store, use, retain, and share your personal information (including your health information as applicable) in accordance with the requirements of the Privacy Act 2020, and the Health Information Privacy Code 2020. The information that we might collect from you, the purposes for which it may be used, how it will be stored, and with whom it may be shared, is set out in this Global Privacy Policy.
In addition, we will take steps to ensure that any Personal Data relating to you is accurate, up to date, complete, relevant, and not misleading before we use or disclose that Personal Data.
If you have any queries, concerns or complaints about the manner in which we have collected, stored, used or disclosed your personal information, or you wish to request access to or correction of Personal Data we hold about you, please contact [insert].
We will treat your complaint confidentially and, after investigating your complaint, discuss the ways in which we can remedy the situation. We will ensure that we respond to your complaint within a reasonable timeframe (and in any event within the time required by the Privacy Act 2020)."
HOW TO EXERCISE YOUR DATA PRIVACY RIGHTS
If you would like to exercise your data privacy rights, subject to applicable local laws, you may contact us by contacting Consumer Affairs. We will respond to your request consistent with applicable law.
For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion), or to be able to honor opt-out requests.
UPDATES TO THIS PRIVACY POLICY
The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.
CONTACTING US
Click here to identify the controller responsible for collection, use, and disclosure of your Personal Data under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact Consumer Affairs or:
Colgate-Palmolive Company
Attn: Global Data Privacy
300 Park Avenue
New York, NY 10022
United States of America
