Kao Americas Region 
Privacy Policy

• What information we collect about you
  
  We may collect various types of personal information, including from the following categories:
  
  • Identity or contact
  • Payment and financial 
  • Transaction 
  • Technical 
  • Geolocation 
  • Profile 
  • Usage 
  • Marketing and communications 
  • Demographic and preferences 
  • Personal or physical characteristics 
  • Audio, visual and sensory 
  
  Anonymous data, or data for which you cannot be identified, is not considered personal information and may be used without restriction or limitation.


• Children’s Online Privacy
  
  We do not direct our websites to minors, and we do not knowingly collect personal information from children under the age of 13. If we learn we have collected or received personal information from a child under 13 without the consent of a parent or guardian, we will delete that information.


• How we collect your information
  
  We may collect your personal information from:
  
  
  • You (e.g., when you communicate with us, complete a form, register an account, etc.)
  • Our websites and emails (particularly via cookies and other automatic data collection tools) 
  • Our affiliates and third parties 
  • User contributions 


• Cookies and automatic data collection technologies
  
  Our websites use automatic data collection technologies, including cookies, flash cookies, and web beacons. We may use Google Analytics and Meta Pixel. We use these tools to distinguish you from other website visitors, to delivery better and more personalized service, and to improve our websites. These technologies may allow us to track your online activities over time and across third-party websites or other online services.


• How we use your information
  
  We may use your personal information for various purposes, including to:
  
  
  • Provide products and services
  • Communicate with you 
  • Conduct marketing and promotions 
  • Administer programs 
  • Perform analytics and to personalize your experience
  • Conduct security and fraud prevention  
  • Comply with our obligations and to protect our rights 
  • Perform core business functions 
  • Facilitate our actual or potential business relationship
  • Accomplish another purpose  
  
  We may use non-personal or anonymized information for any purpose.


• Disclosure of your Information
  
  We may share your personal information with:
  
  
  • Our affiliated companies
  • Our service providers 
  • Our third-party partners 
  • Social media platforms and networks 
  • An acquiring or successor company 
  • Other third parties 
  
  We may also share your personal information with anyone to fulfill a purpose that:
  
  
  
  • you provide it for;
  • we indicate to you when you provide the information; or 
  • is with your consent.
  
  We may share non-personal or anonymized information with anyone without restriction.


• Interest-Based Advertising
  
  Third-party advertisers, content providers or others may serve content or applications on our websites that use automatic tracking technologies to collect information about you, and they may use that information to serve you targeted advertising and content. Your browser settings may not block these technologies, but you may be able to block them via certain platforms of self-regulatory programs.


• Third Party Content, Apps, and Links
  
  Our sites may offer social media plugins (e.g., Facebook, Twitter, Pinterest, etc.). By interacting with a plugin, or by remaining logged into a social media account when you visit our websites, you knowingly transfer information to that social media company, and the collection and use of your information is subject to the social media company’s privacy policy and terms.
  
  If you rate a purchase, review our products, or upload content, or if you tag our brand and we reshare, any such information will become public information.We do not control how others may use, disclose or publish the content that you submit, and we are not responsible for the actions of third parties, even if they do not comply with our privacy policy, the law, or your intellectual property rights.
  We do not control links to third-party websites that might be on our websites. Those websites have their own privacy policies and terms.


• Your Rights and Choices
  
  You may exercise control over your personal information in the following ways:
  
  
  • Subscribe to or opt out of marketing communications
  • Access, correct, update and delete your information 
  • Delete your user contributions 
  • Disable or refuse cookies and automatic data collection technologies
  • Opt out of interest-based advertising
  
  If you are a resident of California, Nevada, Canada, Australia or New Zealand, additional rights and choices may apply.


• Data Security and Risks
  
  We use various safeguards to protect your personal information. But we cannot guarantee absolute security, and there always remains a risk of loss, misuse, unauthorized access, alteration or disclosure.
  
  The safety and security of your personal information also depends on you. Protect your passwords that we give you, and be careful what you post to the public areas of our websites.


• Changes to Our Privacy Policy
  
  We may revise this privacy policy from time to time. The updated version of the policy will be available at this webpage.


• Contact Us
  
  To submit customer service, retail, or press-related inquiries, we have provided a list of our brand contacts, and the mailing address for our companies.
  
  To exercise your privacy rights, we have provided an online webform, as well as a toll-free phone number.


• For California Residents
  
  If you are a resident of California, please see this section for additional disclosures, as well as your rights and choices under California law.


• For Nevada Privacy
  
  If you are a resident of Nevada, please see this section for additional disclosures.


• For Canada Privacy
  
  We will only use your personal information for the purposes described in this privacy policy unless we have obtained your consent, or we are otherwise permitted or required by applicable law.
  
  We may process, store, and transfer your personal information in and to a foreign country, which has different privacy laws that may or may not be as comprehensive as those of Canada. Your information may be accessible to courts, law enforcement and national security authorities in other countries.
  
  We may store your personal information in the Province of Ontario in Canada, as well as the United States and Germany. Personal information will be accessible to our employees who have a “need to know” such information for the purposes described in this privacy policy.
  
  To exercise your privacy rights, including to access or correct your personal information or to adjust your consent, please use one of the methods we have provided in the Contact Us section of this privacy policy.


• For Australia and New Zealand Residents
  
  If you are a resident of Australia or New Zealand, please see this section for additional disclosures.


• Job applicant privacy notice for California Residents
  
  If you are a resident of California and you are applying for a job with one of our companies, please see this section for additional disclosures.

We may collect the following types of information about you: 

• Identity or contact information includes your name, date of birth, mailing or delivery address, email address, telephone numbers, username, or similar identifiers or contact information. 
  

• Payment and financial information includes your billing address, credit or debit card number, and other payment-related information. 
  

• Transaction information includes details about payments to and from you and other details of products you have purchased from us or other details about your transactions with us. 
  

• Technical information includes internet protocol (IP) address, your login data, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites, applications, or connected products, browsing history, and site interactions. 
  

• Geolocation information includes information that allows for determination of your physical location.
  

• Profile information includes your username and password, purchases or orders made by you, your interests, preferences, feedback, age, gender, product reviews, survey responses, information about your experiences with our products, contact preferences, and other similar information. 
  

• Usage information includes information about how you use our websites and our products and services. 
  

• Marketing and communications information includes your preferences in receiving marketing from us and your communication preferences. 
  

• Demographic information and preferences include personal characteristics and preferences, such as your age, gender, shopping preferences, household demographic data, data from social media platforms, hobbies and interests and propensity scores from third parties (likelihood of purchase, experiencing a life event, etc.). 


• Personal or physical characteristics include age (40 years and older), race, ethnicity, ancestry, national origin, citizenship, religion, marital status, gender identity, sexual orientation, military status, genetic information, skin tone and type, hair color and type, and eye color.  


• User contributions and content include product reviews and other feedback that you provide on our products, locations, and services. If you choose to provide user contributions, it may be made available on public areas of our website. 


• Audio, visual and sensory information includes photos, images, videos, and recordings, as well as olfactory and similar sensory data.  

We collect information from and about you in the following ways: 

• From you. You may give us information about you by filling in forms or by communicating with us by text, e-mail, or otherwise. This includes information you provide when you register for an account, subscribe to one of our newsletters or other communications, conduct a search, place an order, engage in a promotional event, complete a survey, or when you contact us about one of our websites, products, or services. We may also collect information when you respond to our request to voluntarily provide information regarding your personal or professional interests, demographics, experience with our products, and contact preferences. 
  
• From our websites and emails. As you interact with our websites or websites employing our cookies, or our emails, we may automatically collect information about your equipment, browsing actions, other activities (like opening emails), and patterns. We may collect this information by using cookies, web beacons, pixels, and other similar technologies. Our Cookies and automatic data collection technologies section contains more information and options to control or opt-out of certain data collection or uses. 
  
• From affiliates or third parties. We may receive information about you from third parties including, for example, our affiliated companies, business partners, sub-contractors, analytics providers, social media companies, and service providers. For example, if you enter a co-branded promotion, that is being sponsored by one of our brands and another party, our co-sponsor may provide us with information about you. As another example, if you sign up for a promotion using your social media credentials, we may receive information about you from that social media company. 
  
• From user contributions. You also may provide information to be published or displayed (“posted”) on public areas of the websites or transmitted to other users (collectively, “User Contributions”). For example, if you rate or review one of our products, then your product review may be made available on public areas of our website. 
  

Our websites use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized service when you browse our website. It also allows us to improve our websites by enabling us to:  

• Estimate our audience size and usage patterns. 
  
• Store your preferences so we may customize our websites according to your individual interests. 
  
• Speed up your searches. 
  
• Recognize you when you return to our website. 
  

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. For information about managing browser settings to refuse cookies, see Your Rights and Choices. 
  
• Flash Cookies. Certain features of our websites may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the website. For information about managing Flash cookies see Your Rights and Choices. 
  
• Web Beacons. Our website pages and e-mails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. For information about managing web beacons, see Your Rights and Choices.
  

We collect and use your information for various purposes, including the following:

• To provide products and services.  We may use your personal information to register you as a new customer, to send you products that you have ordered, to process payment, to provide you with receipts or notifications, to provide updates about the status of your order, and to process product returns.  We may also use your personal information to provide you with information or support, or to send samples that you have requested. 
  
• To communicate with you.  We may use your personal information to manage our relationship with you, which may include notifying you about changes to our terms or privacy policy, providing you with notices about your account, asking you to leave a review or take a survey, and to respond to or address comments, questions or concerns that you may have about our products and services.   
  
• To conduct marketing and promotions.  We may use your personal information to deliver relevant content, advertisements, and messaging, and to measure or understand the effectiveness of such content, advertisements, and message.  We may contact you for market research purposes.  We may also make suggestions or recommendations to you about our products or services that may be of interest to you.  We may also use your personal information to allow you to enter a sweepstake, contest or promotion that we may offer.  Please note that if we offer a co-branded promotion, our co-sponsor may have different privacy practices, which we will inform you about.
  
• To administer programs.  We may use your personal information to administer programs, rewards or benefits, including by setting up and verifying an account, communicating with you regarding the program, evaluating your application, and tracking rewards points. 
  
• To perform analytics and to personalize your experience.  We may use your personal information to use data analytics to improve our website, products or services, marketing, customer relationships, and experiences. 
  
• To conduct security and fraud prevention.  We may use your personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions. 
  
• To comply with our obligations and to protect our rights.  We may use your personal information to comply with contractual, legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim. 
  
• To perform core business functions.  We may use your personal information to maintain records related to business process management, to conduct loss prevention, to collect amounts owed to us, to provide and maintain functionality of our website and apps, to identify and repair errors or problems, and to verify, correct, or update our records and databases. 
  
• To facilitate our actual or potential business relationship.  We may use your personal information in furtherance of our potential or actual business relationship, including if we are exploring a potential partnership in which you would carry or distribute our products. 
  
• To accomplish another purpose.  We may use your personal information for any other purpose either: as we indicate when we collect the information from you; consistent with the purpose for which you provided it; upon your consent; or as required or permitted under applicable law.

We may share your personal information with: 

• Our affiliated companies.  We may share your personal information with any member of our corporate group, including our subsidiaries and affiliates, or our holding company and its subsidiaries and affiliates.
  
• Our service providers.  We may share your personal information with our service providers, contractors, and other third parties that we use to support our business.  The following are some examples of the information that we may provide and the reason for sharing it:
  
  • Your identity or contact information, transaction information, and financial information to our service providers who facilitate and processes payments on our behalf. 
    
  • Your identity or contact information and transaction information to our service provider who follows up with you and asks you to provide a review and rate your purchase. 
    
  • Your identity or contact information and transaction information to our service provider who follows up with you when you abandon your cart and/or assists us with email marketing campaigns. 
    
  • Your identity or contact information, technical information, profile information, marketing and communications information, usage information, and/or your user contributions to our website host and the marketing agency who supports our website and social media channels.
    
  • Your identity or contact information, financial information, transaction information, technical information, and profile information with the software as a service provider that we use to help manage that aspect of our business. 
    
  • Your identity or contact information to a service provider that assists us in verifying, updating and correcting our lists, systems and databases.
    
  • Your transaction information and usage information available to our marketing partners. 
    
  • Your technical information and usage information to our website analytics providers. 
• Our third-party partners.  We may share your personal information with a third-party partner that we work with to jointly create and offer a product, service, or joint or co-branded promotion. 
  
• Social media platforms and networks.  We may share your personal information with social media providers via plugins, widgets, or other tools that are on our website. 
  
• An acquiring or successor company.  We may share your personal information with a prospective or actual buyer or other successor in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which one of the transferred assets is the personal information that we hold. 
  
• Other third parties.  We may also share your personal information with other third parties, including without limitation courts, lawyers or law firms, agents, consultants, and investigators, as required or permitted by applicable law, for reasons that may include (without limitation): 
  
  • To comply with any court order, law, or legal process, including to respond to any governmental or regulatory request. 
    
  • To enforce our Terms of Use and other terms or agreements, including for billing and collections purposes. 
  • To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction. 
  • To investigate suspected violations of any law, rule or regulation, or the terms or policies for our website. 

• you provide it for;  
  
• we indicate to you when you provide the information; or 
  
• is with your consent. 

Some content or applications on our website may be served by third parties, including advertisers, ad networks, social media companies, content partners, or application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies (such as Meta Pixel) to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Our partners may use non-cookie technologies on which browser settings that block cookies might have no effect. Your browser may not permit you to block such technologies. For this reason, keep in mind that you can block the collection and use of information related to you by advertising companies for the purpose of serving interest-based advertising by visiting the following platforms of self-regulatory programs of which those companies are members: 

• The National Advertising Institute’s (NAI’s) opt-out platform: www.networkadvertising.org/choices 
  
• The Digital Advertising Alliance (DAA) U.S. opt-out platform: www.aboutads.info/choices 
• The DAA’s Canadian page: youradchoices.ca/en/tools

Some content or applications on our websites may be served by third parties, content providers and application providers including the following: 

a. Plugins

We may make available the option for you to use “plugins” that are operated by social media companies. If you choose to use one of these plugins, then it may collect information about you and send it back to the social media company that owns it. This may happen even if you do not click on the plugin, if you are logged into the social media website that owns the plugin when you visit our website. Information collected by a plugin is subject to the privacy policy and terms of the social media company that makes it. If you do not want the social media company who owns a plugin to collect information about you when you visit our websites, sign out of the social media network before visiting. By interacting with a plugin when you are on our websites (for example, clicking the Facebook “Like” button), you are intentionally transferring information to that social media company. Further, if you are logged into a social media website when you visit our websites, then you are directing us to share your data with the social media company that owns the plugin. 

We may use the following plugins: 

Facebook
We use the plugins of social network facebook.com, operated by Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA 94025, U.S.A. Please see Meta’s Privacy Policy, which can be found at the following link: Meta Privacy Policy.
Twitter
We use the plugins of social network twitter.com, operated by Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, U.S.A. Please see Twitter’s Privacy Policy, which can be found at the following link: Twitter Privacy Policy.

Pinterest
We use the plugins of social network Pinterest, operated by Pinterest Inc., 505 Brannan Street, San Francisco, CA 94107, U.S.A. Please see Pinterest’s Privacy Policy, which can be found at the following link: Pinterest Privacy Policy. 

YouTube
We use the plugins of the YouTube website, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S.A. Please see Google’s Privacy Policy, which can be found at the following link: Google Privacy Policy.

Instagram
We use the plugins of social network Instagram, operated by Instagram, LLC, 1601 Willow Road, Menlo Park, CA 94025, U.S.A. Please see Instagram’s Privacy Policy, which can be found at the following link: Instagram Privacy Policy. 

TikTok
We use the plugins of social network TikTok, operated by TikTok Inc., 5800 Bristol Parkway, Suite 100, Culver City, CA 90230, U.S.A. Please see TikTok’s Privacy Policy, which can be found at the following link: TikTok Privacy Policy. 

Twitch
We may use the plugins of social network Twitch, operated by Twitch Interactive, Inc., 350 Bush Street, 2nd Floor, San Francisco, CA 94104, U.S.A. Please see Twitch’s Privacy Notice, which can be found at the following link: Twitch Privacy Notice. 

b. User Contributions.
We may ask you to rate your purchases and/or review our products. We may post your ratings and reviews on our website. In addition, in some cases we may allow you to directly upload your own content to public areas of the website. If you tag our brand, we may like or reshare your social media posts. Any information you submit becomes public information, and we do not control how others may use or further disclose/publish the content you submit. We are not responsible for uses or further disclosure / publication by third parties, which may not comply with our privacy policy, the law, or your intellectual property rights. 

c. Third-party links.
Our websites may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms. 

Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.

• Subscribe to or opt out of marketing communications. You can join our email marketing list by entering your email when prompted on our website. If you purchase products from us, we may also send you marketing information about our products. You may opt-out of further marketing communications by contacting Customer Care as set forth below in the Contact Us section or by clicking UNSUBSCRIBE and following the instructions in any promotional email that we send to you. This opt-out may not apply to communications we send related to a product purchase, warranty registration, product service experience or other transaction between us. If you do not want us to use your email address or other contact information to promote or recommend our own products and services, or third parties’ products or services, you can also opt-out by checking the relevant box located on the form where we collect your contact information or, if presented with the option to opt-in, do not opt-in. If you have an account with our website, you may be able to log in and check or uncheck relevant boxes. If you do not have an account, you can adjust your preferences by contacting us as set forth below in the Contact Us section.
  
• Access, correct, update and delete your information. If you have an account with us, you may have the ability to access your information and make updates to or delete your data. If not, or to the extent you wish to access personal information that is not available to you directly, you can contact us as set forth in the Contact Us below to request access to, correction of, or deletion of personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
  
• Delete your user contributions. To request that your User Contributions be deleted, please contact us as set forth in the Contact Us section below. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.
  
• Disable or refuse cookies and automatic data collection technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly. If you do not want Google Analytics to be used in your browser, Google Analytics provides an opt-out tool which can be found here. You may be able to opt-out of Meta Pixel through settings on your Facebook account. Please note that Meta has ultimate control of the information gathered through Meta Pixel. You should consult Meta’s Privacy Policy for potential opt-out options, which can be found here. Finally, in some cases, you may be able to set your browser or email program to not download certain web beacons. 
  
• Opt out of interest-based advertising. Please see Interest-Based Advertising above for information on how to opt-out of interest-based advertising.
  

The security of your personal information is important to us. We use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse and unauthorized access, use, alteration or disclosure. Notwithstanding these measures, “perfect security” does not exist. In particular, we cannot guarantee the security of information communicated to us online or by email. It is possible that third parties may unlawfully intercept or access such information. 
 
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of our websites like message boards, which any website visitor can view. We cannot control the actions of other users of the website with whom you may choose to share information on public areas of our websites. Therefore, we cannot and do not guarantee that such information will not be viewed or copied by unauthorized persons. We are not responsible for uses or further disclosure or publication by third parties, even though it may not be consistent with our privacy policy.

We may revise this privacy policy from time to time.  The updated version of the policy will be available at this webpage.

You may write to Kao USA Inc. or Oribe Hair Care, LLC at:

Kao USA Inc.
Attention: Customer Care
2535 Spring Grove Avenue
Cincinnati, OH 45214

You may write to Molton Brown USA LLC at:

Molton Brown USA LLC
Attention: Customer Care
One Penn Plaza, Suite 4118
New York, NY 10119

You may write to Kao Canada Inc. at: 

Kao Canada Inc. 
Attention: Customer Care 
#2-75 Courtneypark Drive West 
Mississauga, Ontario, L5W 0E3 

You may write to Kao Australia Pty Limited at: 

Kao Australia Pty Limited 
Attention: Customer Care 
Level 2, 293 Camberwell Road 
Camberwell, Victoria 3124 

You may write to Kao New Zealand Limited at: 

Kao New Zealand Limited 
Attention: Customer Care 
Level 2, 109 Wellesley Street
Auckland 1010 

b. To exercise your privacy rights. 
To exercise privacy rights that you may have under this policy or applicable law, please submit your request via our Privacy Web Form, which can be accessed at this link. Alternatively, if you prefer, you may call us toll-free at 1-888-914-9661. If you have general questions, comments, complaints or requests regarding our compliance with this privacy policy or our handling of your personal information, please contact us by either of these means, or via the phone or web links provided in Section 13(A) above.

Nevada residents have the right to opt out of the sale of certain "covered information" collected by operators of websites or online services. We do not currently sell covered information, as "sale" is defined by such law, and we do not have plans to sell this information. 

We comply with applicable Canadian privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act (PIPEDA), in connection with processing Canadian personal information.

We will only use your personal information for the purposes described in this privacy policy unless (1) we have obtained your consent to use it for other purposes; or (2) we are otherwise permitted or required by applicable law to use it for such other purposes.

• Transferring your personal information outside Canada

• Data retention

• Accessing and correcting your personal information

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that would reveal the personal information or confidential commercial information of another person.
• Information that is prohibitively expensive to provide.

In Australia, we comply with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth).  In New Zealand, we comply with the Information Privacy Principles (IPPs) as contained in the Privacy Act 2000 (NZ).

It may be possible for you to deal with us on an anonymous basis (ie, providing no name or personally identifying details), or on a pseudonymous basis (ie, providing a name or descriptor that is different to your true identity).  However, there will be some scenarios where the use of your true identity is a legal requirement (for example, to verify consumer identity, to process and collect payments on transactions, etc.), or where anonymity or pseudonymity will be impracticable.

If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to fulfill the business purposes that we have identified in this policy.  It may also impact your interactions with our various products, services and platforms.  For example, you may be unable to access certain portions of our websites, or you may experience certain limitations in the scope of interactions and services that we can provide.

In the case of “sensitive” personal information (which includes, without limitation, racial and ethnic origin, sexual orientation, health information, etc.), we will comply with the applicable laws of Australia and New Zealand, and will obtain your consent to collection to the extent required by law, and will only collect or use such sensitive personal information to the extent it is necessary for one or more of our functions or activities. 

We make a reasonable effort to respond to verified requests within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing within 45 days of receiving your verified request.

Our business is affiliated with other businesses, organisations and people located overseas.  In the course of doing business with you, we are likely to disclose some of your personal information to these overseas recipients.  We typically only do so where it is necessary to complete the transaction you have entered into, or you have provided your consent, or it is permitted by the relevant privacy and data protection laws in your jurisdiction.  We also take reasonable steps to ensure that the overseas recipients are bound by privacy and data protection obligations.  Our corporate group affiliates and external service providers are located in Australia, New Zealand, the United States of America, Canada, Germany, the United Kingdom, Spain, Switzerland, Italy, Finland, Norway, Sweden, Denmark, the Netherlands, Belgium, the Czech Republic, France, and Austria.