Coway USA Privacy Policy

This Privacy Policy describes how Coway USA, Inc. (“we,” “us,” “our”) processes Personal Information about you. This Privacy Policy describes the Personal Information we gather about you, what we do with it, the safeguards we have in place to protect it, and how you can control our use of it. This Privacy Policy applies when you visit or use any websites or mobile applications where this policy is posted (each a “Site” and collectively “Sites”), contact our customer service team, apply to work for us, purchase our products or services, or otherwise interact with us. 

 

If you are an employee or a job applicant, this Privacy Policy does not apply to personal information collected in the course of your recruitment or employment with us. 

 

If you have any questions, please contact us as provided below.  You may download a copy of this Privacy Policy by using a print to PDF feature in your web browser.  If you have a disability and need to receive this Privacy Policy in a different format, please contact us at privacy@coway-usa.com.

 

Please read this Privacy Policy carefully to understand our policies and practices.  By using the Sites or providing your personal information to us, you consent to the use of your information in accordance with this Privacy Policy. 

Collection of Personal Information

The type of information that we collect depends on your interaction and relationship with us. We may collect the below categories and types of personal information with your consent or as otherwise required or permitted by law. 

·         Contact Information.  We may collect name, postal address, installation address, telephone number, email address, and business contact information.

·         Identifiers.  We may collect IP address, signature and username or email address combined with password or security question and answer. 

·         Financial Information.  We may collect payment card number, payment card expiration date and CVV code, name of card holder, and billing address.

·         Audio/Visual Data.  We collect audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings inside our offices and stores.

·         Commercial Information.  We may collect records of products or services purchased, obtained, or considered as well as purchasing histories.

·         Internet or Electronic Usage Data.  We may collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.

·         Geolocation Data. We may collect geolocation data including the general region or area from which you access our Sites. 

·         Professional or Employment Information.  We may collect your job title, office location, business contact details, and company entity when you contact us on behalf of a third-party. 

·         Inferences.  We may use information from the categories of personal information described above in order to create inferences about you, to reflect your preferences, characters, behavior and attitude.

Sources of Personal Information

We collect information in a variety of ways:

·         Directly from you. We may collect contact information, identifiers, financial information, and commercial information that you provide directly to us.

·         Automatically. When may you access our Sites, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies.

·         When you visit our locations. When you visit our offices or facilities, we also collect contact information and audio/visual data.

·         From third parties. We may collect contact information, identifiers, financial information, and commercial information commercial information, from third-parties including our vendors, service providers, social media platforms, and your references.

Purposes for Collecting and Use of Personal Information

·         Transactional Purposes. We use contact information, identifiers, financial information and commercial information to: (i) process your purchase, rental, return, or exchange of products or services that you lease or purchase; (ii) complete your rental or purchase application; (iii) conduct credit or background checks; (iv) deliver your purchases; (v) communicate with you and provide you with customer assistance; (vi) process payment for your leased or purchased products or services; and (vii) administer contracts with our vendors, clients, and service providers. 

·         Account Creation.  If you choose to create an account, we will collect contact information and identifiers and use that information to create your account.

·         Business Operations.  We use contact information, identifiers, financial information, and audio/visual data, and inferences for our day-to-day business operations including billing and debt collections, procurement, tax-related activities, maintaining records, planning, budgeting, calibration, database administration, surveys, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.

·         Analytical Purposes. We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.

·         Marketing and Promotional Purposes. We use contact information, identifiers, financial information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, provide you with our newsletter, administer surveys, prospect for new customers, customer relationship management, administering promotions, and to provide you with information about us, including personalized marketing communications.

·         Maintenance and Improvement of our Sites and Systems. We use identifiers, geolocation data, and internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems. 

·         Develop and Improve Our Products and Services. We use contact information, identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, audio/visual data, and inferences to help us develop new products and services and to improve and analyze our existing products and service offerings.

·         Security and Fraud Prevention. We use contact information, identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, audio/visual data, and inferences to: (i) protect our Sites, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.

·         Legal. We use contact information, identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, audio/visual data, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

·         Combination of Information.  We combine information we obtain from different sources with publicly available information, including to create inferences about you.  For example, we may combine information that we have collected offline with information we collect online.  We combine information that we have collected across other third party Site.  We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we have.

·         Other Purposes: We use contact information, identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, audio/visual data, and inferences for other reasons we may describe to you.

Disclosure of Personal Information

We disclose personal information to third-parties in the following circumstances:

·         Service Providers. We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, order fulfillment, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.

·         Affiliates. We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.

·         Marketing/Analytics/Advertising Partners. We may share personal information with third party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails.

·         Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.

·         Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.

·         Corporate Transactions. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.

·         With Your Consent or At Your Direction. We may share information with third parties whenever you consent to or direct such sharing.

·         Other Reasons. We may share information for other reasons we may describe to you.

How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future. We use the following criteria to determine retention periods:

·         how long the information is needed to provide our services and operate our business;

·         whether there are contractual or legal obligations that exist that require us to retain the information for period of time;

·         whether any law, statute, or regulation allows for a specific retention period;

·         whether an individual has agreed to a longer retention period;

·         whether the data is considered to be sensitive data; and

·         what the expectation for retention was at the time the data was provided to us.

Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology

We want you to be aware that certain online tools exist to help us serve and recognize you when you visit our website. We receive and store certain types of information when you visit our website. When you access the website, we (including companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications.  These tracking technologies, which are often referred to collectively as cookies, allow us to understand how users navigate to and around our website, view different pages, access content and request Services. We may use them, for example, to keep track of your preferences and profile information and collect general usage and volume statistical information. To learn more about interest-based advertising, tracking technologies, and how to opt out, you can visit http://www.aboutads.info/choices.  You can also change you’re your preferences by clicking “Cookie Preferences” on the website footer.

Do Not Track Signals

Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Google Analytics

We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

Links to Other Websites

Our Sites may include links to other website or applications whose privacy practices may differ from ours. If you submit personal information to any of those website or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use website and share information with caution.

This Website is Not Intended for Children

We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to privacy@coway-usa.com.

Marketing Communications

Marketing Emails.  You can opt out of marketing or advertising emails by using the "unsubscribe" link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at privacy@coway-usa.com. Once we process your request, we will cease using the information for such purposes at no charge to you.  If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.

Phone Calls and Text Messages.  If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us, or reply STOP to a text message from us. You can also opt-out of telemarketing by contacting us at privacy@coway-usa.com.

Processing in the United States

Please be aware that information we obtain about you will be processed in the United States by or service providers or us. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.

California Privacy Rights

Shine The Light. If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please use our privacy request form or call us toll free at 1-855-895-1400 (US and Canada only). For all request, you must provide us with your name, email address, phone number, and mailing address.

California Consumer Privacy Act (“CCPA”).

This section applies to residents of California

Sale or Sharing of Personal Information. We do not sell personal information in exchange for money.  In the 12 months preceding the last updated date below, we have “sold” or “shared” (as those terms are defined in the CCPA) the following categories of personal information: identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences. We do not knowingly sell or share the personal information of minors under the age of 16. 

Use or Disclosure of Sensitive Personal Information. In the 12 months preceding the last updated date below, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

Disclosure for a Business Purpose. In the 12 months preceding the last updated date below, we have disclosed the following categories of personal information to the following categories of third party recipients:

 

Category of Personal Information

Categories of Recipients

Identifiers

·    Service Providers

·    Affiliates

·    Marketing/Analytics/Advertising Partners

·    Professional Advisors

·    Government Entities

Financial information

·    Service Providers

·    Affiliates

·    Government Entities

Commercial Information

·    Service Providers

·    Affiliates

·    Marketing/Analytics/Advertising Partners

·    Professional Advisors

·    Government Entities

Geolocation Data

 

·    Service Providers

·    Marketing/Analytics/Advertising Partners

Internet or Electronic Usage Data

·    Service Providers

·    Marketing/Analytics/Advertising Partners

Audio/Visual Data

·    Service Providers

·    Affiliates

Inferences

·    Service Providers

·    Affiliates

·    Marketing/Analytics/Advertising Partners

 

Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:

·         You have the right to request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information. 

·         You have the right to request that we provide you with a copy of your personal information.

·         You have the right to request that we delete your personal information.

·         You have the right to opt-out of the sale of your personal information.

·         You have the right to opt out of the sharing of your personal information for cross-context behavioral advertising

·         You have the right to direct us to limit the use or disclosure of your sensitive personal information to only the purposes specified in the CCPA.

·         You have the right to correct inaccurate personal information that we hold about you.

·         You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.

Exercising Your Rights. To exercise any of your rights, please use our privacy request form or call us toll free at 1-855-895-1400 (US and Canada only). For all request, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.  In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at privacy@coway-usa.com

Cross-Context Behavioral Advertising.  We engage in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising.  In addition to submitting the form above, you may need to disable sharing through cookies set by third parties on our Sites. To manage your cookie preferences, please click “Cookie Preferences” on the website footer and ensure that analytics and advertising cookies are disabled

Global Privacy Control and Opt-Out Preference Signals

Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “global privacy control” or other opt-out preference signals.  We will respond to these signals in a frictionless manner.   If you have enabled Global Privacy Control or an opt-out preference signal on your browser or extension, we will honor such requests that can be recognized by our Sites by disabling analytics and advertising cookies.  Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address.  You will also  only be opted out of online sales or sharing of personal information through your use of , and will need to turn it on for each browser you use.  Refer to the “Exercising Your Rights” above if you would like to extend your opt-out request beyond the online advertising practices described above.  Please note that If you configure this setting on your browser, certain features on our Sites may not work and you will receive less targeted advertising.  You will also need to turn the setting on for each browser that you use.

Contact Us

If you have any questions about this Policy or our data practices, please email us at privacy@coway-usa.com

Updates to Our Privacy Policy

From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates.  The “Last Updated” legend below indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites.

Effective Date: March 2, 2020

Last Updated:  November 3, 2023

Do Not Sell or Share My Personal Information


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