Effective Date: 20 February 2023

Kiiroo B.V. Website Privacy Notice

At Kiiroo, (“Kiiroo”, “we”, “our”) we know privacy and security are important to you.

This Privacy Notice applies to the personal data we collect when you use the Kiiroo website at Kiiroo.com (https://kiiroo.com). The website is owned and operated by Kiiroo and our contact information is set out below.

Certain Kiiroo products (“Products”) may be paired with the FeelConnect application (the “App”) that you can install on your mobile device. The privacy and data practices related to the App are set out in the FeelConnect App Privacy Notice, which can be found at https://feeltechnology.com/feel-apps-privacy.html.

Collection and Use of Personal Data

We collect and use your personal data on our website for the purposes identified below.

Kiiroo Online Store

When you purchase a Product from the Kiiroo online store, we collect your name, email address, phone number, billing and shipping address, a password, and payment card information. We use this information to process your transaction, deliver your order, register your Product for warranty purposes, and administer your account.

Warranty Requests

You may submit a warranty request for Product replacement on our website in the event that your Product fails to work due to a defect in workmanship or materials. To process your request, we ask for your personal data including your name, email address, phone number, residential address, Product type, serial number, the date of such purchase, proof of purchase (i.e., an image of the receipt of purchase), reason for the warranty request, pictures and videos to verify the defect or incorrect item, and any additional information you wish to provide. We use this information to process your request for warranty coverage.

Communications

You can sign up to receive emails about promotions, news and other information about Products and services on our website. We collect your email address for the purpose of sending you these communications and for marketing purposes.

You can opt out of receiving these Kiiroo communications at any time by following the unsubscribe instructions included in each email message, or by contacting us

([email protected]). Please note that you may continue to receive transactional or informational emails from us.

Contact Us

When you contact us with a comment, question or complaint, or when you use the live chat feature for support, you may be asked for information that identifies you such as your name, email address and country, along with additional information we may need to help us promptly answer your question or respond to your request, comment or complaint. We may retain this information to assist you in the future and to improve our customer service. We also use your personal data to establish and manage our relationship with you and provide quality service.

Information We Collect Automatically

We and our third-party service providers (see below), including Google Analytics, collect, process, store and analyze information obtained from your browser or through the use of “cookies” or other tools that track, measure and analyze the behaviors and usage patterns of visitors to our website. We use the word “cookie” in this Privacy Notice to refer to all such cookies and other tools.

A cookie is a tiny element of data that our website can send to your browser, and can then be stored on your computer or mobile device, so we can recognize your computer or mobile device when you return.

We use the following cookies on our website:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into your account or make use of online payment services.
  
  
• Functionality cookies. These are used to recognize you when you return to our website and to embed functionality from third party providers. This enables us to personalize our content for you, remember your preferences (for example, your choice of language) and to integrate useful services provided by third party providers into our website.
  
  
• Analytical cookies. We use Google Analytics to collect certain analytical information to help us better understand activity on our website and improve our services and the quality of our website. This information includes the IP address, Product type and identifier, and related information such as page requests, referring websites or ads, operating system and browser, time spent on our website, and actions taken in the Kiiroo online store. We receive this data in an aggregated, anonymous form. We use this information to help us understand how visitors engage with our website, measure the effectiveness of our advertising on third-party websites, and to improve our visitors’ experience.

You may set your web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all the features of our website. To find out more about cookies, including how to see what cookies have been set, and how to adjust your browser settings to block cookies, visit www.aboutcookies.org or www.allaboutcookies.org.

You can obtain additional information on Google Analytics’ collection and processing of data including how to opt out by clicking on the links provided: (https://www.google.com/policies/privacy/partners/) and data privacy and security (https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008).

Legal Basis for Processing

For the purposes of this website, Kiiroo is the data controller for processing of personal data as defined under applicable data protection law. We process personal data for the purposes set out in this Privacy Notice, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract between you and Kiiroo (for example, to provide you Products and services through our website and to process your payments); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve our services); and based on your consent (for example, to communicate with you about our Products and services), which may subsequently be withdrawn at any time (by contacting us at the email address below) without affecting the lawfulness of processing based on consent before its withdrawal.

In some instances, you may be required to provide us with personal data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our website.

Sharing of Personal Data

We do not sell or disclose your personal data to third parties without your consent, except as set forth below, or as required or permitted by law.

Service Providers

Your personal data will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to administer certain functions such as payment processing, hosting our website, provide technical support, shipping, marketing campaigns, and managing and analyzing data and our advertising effectiveness. Our service providers are given only the information they need to perform their designated functions and are not authorized to use or disclose personal data for their own marketing or other purposes.

Legal and Compliance

We and our service providers may disclose your personal data if we have a good faith belief that such disclosure is necessary in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable EU law or legal process. Your personal data may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business

Personal data may be provided to third parties in connection with a business transaction, including a prospective or completed merger, acquisition or stock sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Kiiroo, or as part of a corporate reorganization or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Transfers of Personal Data

We, and the service providers with whom we share your information (as set out above), may transfer to and store the information we collect about you in countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area (“EEA”), in accordance with applicable law. In the event that personal data is transferred to the U.S. or another foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. While the United States and other jurisdictions may not offer the same level of privacy protection as your own country, we commit to uphold the privacy protections as explained in this Privacy Notice. We take steps to comply with applicable legal requirements providing an appropriate level of protection for the transfer of information to countries outside the EEA, and ensure that recipients of your information are bound to duties of confidentiality.

By submitting your information to us and using our website, you acknowledge this transfer, storing and processing of your personal data.

Safeguarding and Retention of Personal Data

We have implemented administrative, technical and physical measures designed to help safeguard personal data in our custody and control against theft, loss and unauthorized access, use, modification and disclosure.

We restrict access to information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have information retention processes designed to ensure that we will retain your personal data only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our services.

Your Rights

Subject to applicable law, you may have certain rights with respect to our processing of your personal data. You may have the right to request access to the information we hold about you, obtain confirmation as to whether or not information concerning you exists, be informed of the content and source of such information and check its accuracy. You may also have the right to correct, update, delete, block, cancel, copy and transfer (i.e., the right of ‘portability’), or object to the use of, your information held by us.

If you change your mind and no longer wish to receive marketing communications from us, you have the right to request that we cease sending marketing communications, whether by email or otherwise, to you. You can do this by:

• checking the applicable box(es) on any form we may use to collect information from you;
  
• clicking the unsubscribe link displayed in any of our marketing e-mails; or
  
• otherwise requesting that we do not process your information for marketing purposes.

If you consider that our processing of your personal data infringes applicable law, you may lodge a complaint with a competent supervisory or regulatory authority, which may be the authority in your jurisdiction of residence or work.

Additional Information

Third Party websites

The website may contain links or plug-ins to other third-party websites, including social media websites, that are not owned or controlled by us. Links to our website may also be featured on websites on which we advertise. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link or plug-in, you will leave our service and go to another site. During this process, another entity may collect personal data from you. If you engage with our content or through social media websites and plug-ins, you may allow us to have access to certain information associated with your social media account (e.g., name, username, profile picture, gender) to deliver the content or as part of the operation of the social media website or plug-in.

Updates to the Privacy Notice

We may update this Privacy Notice periodically to reflect changes to our privacy and data practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will post a prominent notice on our website to notify you of any changes to our Privacy Notice, prior to the effective date of the change, and, in some cases, will provide notice of the changes by email. We will indicate at the top of this Privacy Notice when it was most recently updated.

 

Contact Us

If you have any questions or comments about this Privacy Notice or the use of cookies; if you would like us to update information we have about you or your preferences; or to exercise your rights of access, rectification, blocking, or deletion, or to object to the processing of your information, please contact our Privacy Officer by email at: [email protected] or at:

Attn: Data Protection Officer Kiiroo B.V.

De Boelelaan 7 Amsterdam, North Holland, 1083 HJ, Netherlands