Privacy Policy
Updated on 03 October, 2023
Privacy is always the first priority of KEF in order to protect our customer’s rights and Personal Information. This Privacy Policy (“Policy”) explains the processing of Personal Information and Non-Personal Information that relates to each individual in connection to KEF’s environment, which includes but not limited to our products, website, mobile application, store visits, interaction on social media platform, SMS and physical locations, such as an exhibition booth and store (“KEF’s Environment” or “KEF’s Resources”). These environments are managed by GP Acoustics International Limited and/or together with its subsidiaries and affiliated companies (collectively referred to below as “KEF”, “we”, “us” or “our”) as listed under Section 15 of this Policy.
KEF is committed to compliance with the applicable regulatory and legal requirements in which we operate, and when we collect, use, hold and process Personal Information. This Policy sets out the general terms of Personal Information handling while additional terms for access and usage for specific regions are listed in Section 16 of this Policy.
As an on-going practice, we will continuously review our Privacy Policy and monitor our privacy controls to protect the Personal Information with the assurance of data subject right. Therefore, we reserve the right to revise and change the provisions of this Policy at any time. Customers are advised to review this Policy from time to time. We will also provide notification through possible channels to the applicable customers on the changes that have been made on the Policy with the option to withdraw their consent to the Privacy Policy.
1. Your Right As A Data Subject
You may exercise your right to know whether we hold your Personal Information, what type of Personal Information is held and request access to, correction of, or deletion of your Personal Information held by us. We will provide you with a response in accordance with applicable data protection law. KEF may refuse to provide such information in limited circumstances under applicable local law. You may send such requests or contact us through our contact information as described in Section 15.
- have access to your Personal Information, for which we may charge a reasonable fee for complying with your request;
- correct any Personal Information relating to you which is inaccurate;
- remove any Personal Information relating to you;
- withdraw your consent to the use of your Personal Information by us (however, withdrawing consent may affect your access and use of our App and/or Website); or
- restrict or object to processing of your Personal Information by us,
You also have the right to lodge a complaint before your local data privacy authority should we violate applicable data privacy laws(s) in our processing of your Personal Information.
You or your authorized representative may make a data subject right request through methods as described in Section 15. Note that to respond to your request, you or your authorized representative must provide sufficient information that allows us to reasonably verify your identity and request, which includes but not limited to email address, name, copy of documents for proof of your identity and purchase record, phone number. If you use an authorized representative to submit such a request, we will also require the written permission or a copy of the power-of-attorney document granting that right. We will respond to your request within the timeframe requirement under applicable privacy regulations and provide details of data subject request handling process.
Personal Information may be located outside KEF’s environment which is not owned or controlled by KEF, i.e. third parties as described in Section 9. To execute your data subject right, you may also have to contact the corresponding third parties. Please refer to Section 9 or contact us through our contact information as described in Section 15 for more information.
2. Personal Information Processing and Collection
“Personal Information” is any information that can identify a person individually and includes, without limitation, name, e-mail and/or postal address, telephone number, username, password, date of birth, gender, credit card number, billing and/or other contact information. KEF will only process, collect and store your Personal Information under any of the following reasonable justifications:
- Consent: You have given explicit consent for KEF to process, collect and store your Personal Information for the specified purpose.
- Performance of a Contract: KEF process, collect and store your Personal Information for the purpose of entering or performing a contract with you given that you have accepted the contract and willingly provided these Personal Information to us.
- Legitimate Interest: It is necessary for KEF to process, collect and store your Personal Information to reasonably maintain the interest of KEF and any associated third party, under the circumstances that it does not override your fundamental rights and freedoms.
- Compliance with Legal Obligation: It is necessary for KEF to process, collect and store your Personal Information to fulfil legal/regulatory obligations of countries that KEF operates.
3. What and How Personal Information is Collected From You
The following are the most common situations when we may collect and store your Personal Information, and by using the Website and/or App and/or visiting KEF Physical Locations, you agree to us collecting your Personal Information through the following means, although these means are not exhaustive:
- registration to use the App and/or Website;
- browsing, using, purchasing products, signing-up for KEF’s newsletters through the App and/or Website and/or otherwise using KEF’s services through the App and/or Website
- visiting KEF’s point of sale locations and marketing campaigns;
- visiting KEF’s social media platforms, including but not limited to KEF’s Website, Facebook or Instagram pages and creating user-generated content on those platforms (such as comments, discussions, likes, private messages, etc.);
- visiting KEF’s social media platforms to communicate with us on any enquiries;
- submission of surveys and/or event questionnaires (e.g. via webforms on the Website) and entry into sales promotions;
- registration for product warranties and maintenance services;
- requests for customer service or other assistance on the App and/or Website;
- contacting us by email, post, fax or any other means of communication.
For any collection of Personal Information from a third-party, KEF will endeavour to comply with the privacy policies of the corresponding third-party’s privacy policy and the applicable local regulatory requirement. This includes the Personal Information collected from social media platforms, and KEF will only collect and store such Personal Information that we are permitted to collect by these social media platforms.
You have the right to refuse to provide your Personal Information; however it may affect your access to corresponding services and products. Please refer to Section 3.1 and 3.2 for more information.
3.1 Personal Information Collected From You Directly 
| Category | Personal Information | Collection Channels | Purpose | Justification |
|---|---|---|---|---|
| Membership* , Customer Service and Relationship Management | Name, Email, Date of Birth, Phone Number, Gender, Residence Address, Password, Purchase Record, Usage Records, Survey Results, Customer Feedbacks | KEF Website KEF APP KEF’s Physical Location Other communication channel, including but not limited to email, KEF’s social media channels and pages | Register, verify and manage your account on the APP and/or Website. Compile, maintain and update our database of users on the App and/or Website.* | – Performance of a Contract* – Consent* |
| Contact us for any support or customer support service as address customer’s enquiry. Provide aftersales customer/ technical support for our products and services. | – Performance of a Contract – Legitimate Interest – Consent | |||
| Customer relationship management (such as conducting customer surveys) as well as other administrative purposes which is considered as necessary at customer’s legitimate interest in relation to the APP and/or Website and/or KEF’s Physical Locations. | – Legitimate Interest – Consent | |||
| Communication about the changes to our policies or terms and conditions. Detecting, investigating and preventing activities that may violate our policies or terms and conditions. | – Legitimate Interest | |||
| Online, Purchase and Website Experience | Name, Email, Credit Card Information, Shipping Address, Phone Number, Invoice Number, Order Date, Digital Identifier such as an IP address or a cookie ID | KEF Website* KEF’s Physical Location | Processing your purchase orders (whether on the Website, at KEF’s Physical Locations or otherwise) and contacting you regarding your purchase orders if necessary, as well as arranging delivery of the purchased goods. | – Performance of a Contract |
| KEF Website | Facilitate your log-in access and experience on the Website including through the use of cookies, as described above, e.g. establish and maintain your logged-on identity so that you can conveniently browse, access and use the Website without being requested to log-on repeatedly.* | – Consent* | ||
| Obtaining various types of demographics information from our Website, which we use to operate, monitor, customize, enhance, maintain, optimize and/or improve the Website and better goods and/or services offering. | – Legitimate Interest – Consent | |||
| Analytics and Experience Customization (as described in Section 7 & 8) | Digital Identifier such as an IP address or a cookie ID | KEF Website | Create customer profiles and conduct analytics on activity records, to which we use to operate, monitor, customize, enhance, maintain, optimize and/or improve the KEF’s environment and better goods and/or services offering. | – Legitimate Interest – Consent |
| Product Support and Enhancement | Name, Email, Phone, Date of Purchase, Product ID, Retailer, Purchase Price, Residence Address, Device Information, Usage Patterns, Geolocations, Survey Results, IP Address, Cookies, Speaker firmware Version, Region, User enquiry description, Image, Video, Speaker serial number, Speaker logs, App logs | KEF Website KEF APP KEF’s Physical Location | Register for product warranty, provide product maintenance services, and customer/ technical support. | – Performance of a Contract |
| Collect customer inquiries, diagnose and provide feedback. | – Consent | |||
| APP and product improvement. | – Legitimate Interest | |||
| Speaker System Management | Speaker MAC address (to identify your speaker), KEF ID | KEF Speaker and Product | Conduct analytics on speakers and KEF’s product to provide device safety, essential operation, monitoring and maintenance. | – Legitimate Interest |
| Marketing Campaign (as described in Section 5) | Name, Email, Phone Number, Social Media Account Details, Date of Birth, Gender, Age, Address, Survey Results | KEF Website KEF APP KEF’s Physical Location | Administering contests, competitions and promotions including informing you of a prize you have won. | – Consent |
| Receive KEF’s update that may include but not limited to promotion, discount and new product. | – Consent | |||
| Communicating with you about your account and sending you information about our products and services, as well as features of the Website. | – Consent | |||
| Reviewing, improving and strengthening our marketing strategies, advertisement, promotional materials and content of the Website, including without limitation to formulating and/or conducting market analysis and research, such as interviews and focus groups. | – Consent | |||
| Geolocation & Device Identification (as described in Section 6) | IP address (limited to general location identification), MAC address | KEF APP | Provide local music streaming service based on your location. | – Legitimate Interest – Consent |
| Connect KEF Apps with KEF products to for initialization and customization of the product. | – Legitimate Interest – Consent | |||
| Check and auto-set the Wi-Fi, channel and power settings of KEF’s devices according to your location. | – Compliance with Legal Obligation |
3.2 Personal Information Collected From Third Party
| Category | Processed Data | Collection Channels | Purpose | Justification |
|---|---|---|---|---|
| Social Media Interaction | Name, Email, Phone Number, Social media Account Details, Date of Birth, Gender, Age, Address, Survey Results | KEF’s social media channels and pages, including but not limited to Facebook, Twitter, Instagram, Line, WeChat, Weibo, Xiaohongshu # JINGdigital # | Address any enquiry through social media platform; or communicating with customer who reach to KEF through social media channel. | – Consent |
| Join and follow KEF’s social media channel; comment, post or share any material to/from KEF’s social media platform. | – Legitimate Interest | |||
| Visiting KEF’s social media platforms with the aid of creating user-generated contents on those platforms. | – Legitimate Interest | |||
| Third Party Campaigns | Name, Email, Phone Number, Social media Account Details, Date of Birth, Gender, Age, Address, Survey Results | Third Party websites, social media pages, and physical locations | Receive KEF’s update that may include but not limited to promotion, discount and new product. | – Consent |
| Data from Business Partners (e.g. Distributor/ eFranchise) | Name, Email, Phone Number, Social media Account Details, Date of Birth, Gender, Age, Address, Survey Results, Invoice Number, Order Date | Business Partners database | To perform product purchase, support and marketing activities for data subjects who submit their requests through distributors/ eFranchisees. | – Performance of a Contract |
4. Non-Personal Information Processing And Collection
“Non-Personal Information” includes aggregated and/or automatic information collected about use of KEF’s resources or about a group or category of users, which individual identities with its identifiable information have been stored separately, and replaced by an automatically generated ID (“KEF ID”) to create KEF ID profiles for further processing. Reasonable efforts have been committed by KEF to govern the usage and transfer of KEF ID profiles, such as access control, encryption and contractual agreements, to prevent individuals from being identified from these non-Personal Information. KEF commits with the best effort to avoid identifying any individual from the collected non-personal unless at KEF’s legitimate interest or data subject’s benefit to do so. We and/or our data processors (which process non-personally identifiable information on our behalf) may also keep non-Personal Information to form activity logs and diagnostic data may be automatically collected when you are using KEF’s resources and products. It may be mandatory for us to collect some of the non-Personal Information to ensure the proper functioning of these resources and products.
As these are considered as non-Personal Information, to the extent that the laws of certain jurisdictions allow, this Policy should not restrict or limit our collection, use and provision of non-Personal Information. To provide transparent handling and processing of personal information that may relate to a data subject, the following illustrates the processing of non-Personal Information.
4.1 Non-Personal Information Collected
| Category | Non-Personal Information | Collection Channels | Purpose |
|---|---|---|---|
| Essential Speaker System Data (Mandatory for basic functionality of the speaker) | Device temperature, Device power management, MAC address (to identify your speaker), KEF ID, Firmware version, Firmware update status, Production batch, Region Device name, the geolocation information and other unique device identifiers of the device accessing the App and/or Website, browsing preferences such as region, language settings, etc., as well as the App version accessed by you; | KEF Speaker | Monitoring speaker system performance and capturing any critical performance issues. This information helps us to guide product improvement and customer support decisions. |
| App usage behavior (Optional) | KEF ID, App version, Speaker firmware version, Speaker MAC address, Region, Sources used over time, Speaker engagement time, Volume settings per source, Remote control interaction, Speaker color, EQ settings preferences, Speaker settings | KEF APP | Providing better insight into how our users interact with our speaker and app This will help improve our current app and our future product offerings. |
| General Speaker Analytics (Optional) | KEF ID, Firmware version, MAC Address (to identify your speaker), Sources used over time, Speaker engagement time, Volume settings per source, Remote control interaction, Speaker color, Speaker settings | KEF Speaker | Providing better insight into how our users interact with our speaker. This will help improve our current speaker and our future product offerings. |
| Product and Mobile Application Experience | Application Customization such as App Home Screen Settings, Speaker EQ Settings | KEF APP | Store and retrieve customer preferences on customization features of the KEF App. |
| Information about your use of the App and/or Website including without limitation the specific actions you take on the App and/or Website, the number of new or returning visits, statistics on the pages visited and referred, a reading history of the pages you have viewed, search terms used and search results, error and crash statistics, traffic data (such as time and date of access); | KEF APP | Use the information in the speaker and/or KEF App logs to supplement bug reports submitted by the users, used by developers to handle and fix bugs and crashes of KEF’s speaker and/or product. |
5. Use of Personal Information in Direct Marketing
We also intend to use your Personal Information in direct marketing, but we will not do so without obtaining your prior consent. Your explicit consent on direct marketing is mandatory for us to deliver any marketing material to you.
Our direct marketing activities in general are defined as KEF Updates, which may include communication by post, telephone, email, SMS, App notifications and/or other mobile communication applications (such as WhatsApp, WeChat and/or Line) about KEF’s environment as well as our products, services, newsletters, events, contests, competitions, surveys, offers and promotions connected with the audio and/or electronic goods and services provided by us.
When you first register for an account on the Website and/or the App or when you first provide your Personal Information to us at KEF Physical Locations or through other means of communication such as email, if you do not want your Personal Information to be used for direct marketing purposes, please do not tick the checkbox which allows you to opt into our newsletters and/or direct marketing activities.
You may also change your mind and request that we stop sending you direct marketing materials/communications or to cease using or providing your Personal Information for any direct marketing purposes at any time by following the opt-out / unsubscribe facility provided in our marketing materials or through our contact information as described in Section 15. We will, at no cost to you, act on your request to ensure that you are not included in future direct marketing promotions.
6. Source Location Data Processing and Collection
When accessing KEF’s resources, IP address location tracking or other means of technologies might be used to determine and collect information about the current location of your device, given that if the location tracking feature is enabled on the device. This geolocation data is collected anonymously in a form that does not personally identify you. The current location of your device will be stored locally on your device which will be used by the App and/or Website to serve you certain contents tied to the relevant location, and facilitate the initial setup of KEF’s products. The basis of your location is being collected include certain regulatory requirement in specific jurisdiction or consider as mandatory to provide KEF’s services for product usage.
If you elect to have your location-based searches saved to your history, we will store such information on our servers. In addition, only generic location such as country or region is being collected with the purpose as illustrated below:
- Customize and provide relevant information that relates to you.
- Enhance your browsing experience.
- Deliver advertisements according to your region.
- Address your enquiry and provide customer support through our regional representative.
A customer may always choose to restrict the sharing of location data by disabling the location tracking feature from the device and/or browser at any time. Disabling the location tracking feature will not affect your access or use of KEF’s resources, but it may deliver information and contents that are less relevant to your location.
7. Use of Cookies
Cookies are small text files that are stored on your mobile device when you access the App or Website, and they record your preferences and actions when accessing the same. We use cookies to track the use of and the browsing behavior on the App and/or Website, as well as to monitor traffic, to maintain and improve the App, and to customize, enhance and optimize your browsing experience on the App and/or Website to make it easier and/or more convenient for your use. For details of how we use cookies, please refer to our Cookie Policy.
8. Use of Personal Information In Automatic Processing
We intend to collect your usage behavior for the purpose of automatic processing including but not limited to profiling and automatic decision making. Automatic processing is used to optimize KEF’s service and product offering, and improve your experience as a customer.
When you use our App and/or Website, we may collect your usage behavior based on your engagement with various elements, such as subscription to direct marketing activities and purchase frequency, and create usage profiles. Analyzed results of your usage behavior will help shape the way of us providing you with a more customized online experience.
KEF values your own preference on how you want your service to be customized. You may request us to cease using your usage behavior for automatic processing through our contact information as described in Section 15.
9. Personal Information Transfer From/To Third Party
KEF is committed to take every measure to keep your Personal Information secure and confidential. KEF does not exchange, nor transfer Personal Information with third parties for any purpose, including direct marketing. Share, sell, transfer, provide, rent or trade of Personal Information is not permitted unless we have obtained your consent or with legal basis in accordance with the requirements under the applicable law, except to carry out contractual obligations, fulfill purchase orders, by our legitimate interest, under the condition of KEF that all or substantially all of our assets are sold/ transferred to another party, or requested by government agencies.
With the consideration of justified and legal grounds, we may transfer your Personal Information from/to third parties and will only seek your consent to do so if this is required by your local law. These parties will only process your Personal Information for and on our behalf as set out in this Policy or required by the local regulatory requirement and will not process your Personal Information for their own purposes. They owe a duty of confidentiality to us and we require them to contractually agree to hold, process and use your Personal Information in compliance with this Policy and in accordance with our instructions. In any circumstances the third parties act as a controller of the Personal Information, the user should be aware that respective privacy policy of the third parties should be referred.
Although the third parties should only process Personal Information as set out in Section 3, additional processing and collection of Personal Information may take place if the customer is subscribing or using further services from these third parties where KEF is not responsible or liable for these activities as we have no control over how the third party will use, process or share your Personal Information. Hence, if a user is using the third-party in any means other than the purpose as stated in Section 3, it is highly suggested to read and agree their respective privacy policies before connecting with any Third Party Services from KEF.
9.1 List of Third Parties
| Category | Personal Information | Purpose |
|---|---|---|
| KEF’s Affiliates or Subsidiaries | Name, Email, Phone number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Financial and accounting purpose; meeting the purpose of processing as stated in Section 3. |
| E-commerce Platform and Technology Provider | Name, Address, Email Address, Phone Number, Social Media Account, Digital Identifier such as an IP Address or a Cookie ID. | Conduct sales related activities and/or offers our products for sale for the purpose of processing your purchase orders, sales delivery, conduct KEF’s marketing campaigns as well as any other purposes as specified under Section 3 above for and on KEF’s behalf. |
| Installment and Payment (Possible Recipient: Klarna, Splitit) | Name, Email, Phone Number, Address, Credit Card Information, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Provide payment settlement with installment options through service provide to settle purchase order. |
| Third Party Warehouse and Logistics | Name, Email, Phone Number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Arrange delivery of the goods you have purchased from KEF’s Environment. |
| Fraud Prevention Tool (Possible Recipient: Signifyd) | Name, Email, Phone Number, Address, Credit Card Information, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Detect, prevent or address fraud or security issues; protect against harm to the rights, property or safety of KEF. |
| Social Media Platform (Possible Recipient: Facebook, Apple, Line, Google, Twitter etc.) | Name, Email, Phone Number, Social media Account Details, Date of Birth, Gender, Age, Address, Survey Results, Digital Identifier such as an IP Address or a Cookie ID. | Connect your KEF membership account or App with such Third-Party Services for login. |
| Obtain various types of non-personally identifiable demographics information; operate, monitor, customize, enhance, maintain, optimize and/or improve the App and/or Website. | ||
| Address any enquiry / communication through social media platform; Join and follow Sound of Life’s social media channel; comment, post or share any material to/from Sound Of Life’s social media platform; Visiting Sound of Life’s social media platforms with the aid of creating user-generated contents on those platforms. | ||
| User Authentication Service | Name, Address, Email Address, Phone Number, Social Media Account, Digital Identifier such as an IP Address or a Cookie ID. | Verify your identity on KEF’s APP or website. |
| User Behavior Analyzer Tools | Digital Identifier such as an IP Address or a Cookie ID. | Obtain various types of non-personally identifiable demographics information; operate, monitor, customize, enhance, maintain, optimize and/or improve the App and/or Website. |
| Product Repairing Service | Name, Email, Phone number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Provide product repairing services and contact customer for follow-up and service delivery. |
| Outsourced Customer Service | Name, Email, Phone Number, Address, Invoice Number, Order Date, Video, Photo | Provide customer support services to address customer’s enquiry. |
| Authorized Dealer | Name, Email, Phone Number, Address, Invoice Number, Order Date | Provide sales and aftersales services for KEF’s products. |
| Distributors | Name, Email, Phone Number, Address, Invoice Number, Order Date | Manage product supply and distribution of KEF’s products, and provide customer support services. |
| Marketing Agencies and Consultant | Name, Email, Phone Number, Social Media Account Details, Date of Birth, Gender, Age, Address, Survey Results | Conduct KEF’s marketing campaigns; Review, improve and strengthen our marketing strategies, advertisement, promotional materials and content of KEF’s Environment. |
| Outsourced Application Vendors | Name, Email, Phone Number, Social Media Account Details, Date of Birth, Gender, Age, Address, Survey Results | Provide support and maintenance to KEF’s App and/or Website |
| Home Automation Service | Name, Address, Email Address, Phone Number, Social Media Account, Digital Identifier such as an IP Address or a Cookie ID. | Connect your KEF products to home automation applications and/or products. |
Remarks 2: The above list is not applicable if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the Republic of Korea. Refer to Section 16.2 for more information.
Remarks 3: The above list is not applicable if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the People’s Republic of China. Refer to Section 16.3 for more information.
10. Children’s Privacy
We do not knowingly collect Personal Information from children aged under 16 or individuals under the age of majority in the country that they live. If you believe that we have inadvertently collected such information, please contact us through our contact information as described in Section 15 so that we can promptly obtain parental consent or remove the information.
11. Data Security
We take reasonable administrative, physical and electronic measures designed to safeguard and protect your information from loss, destruction, misuse, unauthorized access, disclosure and alteration. Physical records of your Personal Information will be stored in locked cabinets in a secure location with restricted access. Electronic copies of your Personal Information will be stored on servers maintained by us and/or our third party service providers, which are situated in secure locations and protected by adequate data security measures. Your Personal Information will be stored in an encrypted form behind a firewall designed to block access from outside our network.
While we try our best to safeguard your Personal Information once we receive it, no security or encryption method can be guaranteed to protect information from hackers or human error, and no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
Our Website and/or App may contain links/connection to third party websites/resources, including external music streaming platform and audio correction solution connection through our APP. These links/connections are provided solely as a convenience. KEF does not endorse any third-party websites/resources. Access to any other website/resources through any links/connection provided on our Website and/or App is at your own risk. KEF is not responsible for the content of any such websites/resources or the accuracy or reliability of any information, data or other contents of those websites/resources. Your Personal Information will not be transferred from / to third party unless as described in Section 3.2 and 9, or regional terms in this Policy (Section 16). We encourage you to consult the privacy policies of any third party websites/resources that you visit.
12. Data Retention
We will not keep your Personal Information for longer than necessary to fulfil the purposes and any directly-related purposes for which such Personal Information is collected. We will take into account any financial regulations and legal obligations that require us to retain the Personal Information for a certain period of time as well as the duration of your use of our Website and App. We will also keep your Personal Information as long as necessary for the purpose of KEF’s membership and at your own interest. If you wish to de-register from our Website and/or App, amend, update, remove your Personal Information, or request that we no longer use your Personal Information to provide you with the information or services you have requested, please contact us through our contact information as described in Section 15.
13. International Transfer and Location of Data Processing
The information that we collect may be processed globally and transferred internationally. The countries involved in Personal Information transfer, usually in a form of information processing facilities, includes EEA (including an EU Member State), the United Kingdom, the United States, Hong Kong, Singapore, Taiwan, Japan and Dubai as well as any country where we and KEF’s affiliates or subsidiaries. In addition, the processing location also include the service providers and other third parties with whom KEF may share information (as described in Section 9) may be based outside of the country of your location. Unless stated by the regional terms in this Policy (as described in Section 16), if you are accessing the KEF’s resources or by providing us with your Personal Information, you consent to the transfer of your Personal Information to our facilities outside of the country in which you have provided your Personal Information to us.
The Personal Information protection laws of those countries where your Personal Information are stored might not be as stringent or comprehensive as those in your country, but we will take all reasonable steps to ensure the protection of your privacy and will only collect and use your Personal Information for the purposes which are set out in this Policy. In any case, KEF will implement appropriate contractual measures, such as standard data protection clauses and data transfer agreement, to ensure that the relevant KEF entities and third parties provide an adequate level of protection to your Personal Information as set out in this Policy and as required by applicable local law. To comply with the applicable local law, your Personal Information may be accessed by the local legal authorities.
14. Your Obligation to Keep Your Access Rights Secure
If you register an account on our Website and/or App, you are entirely responsible for ensuring and protecting the security and confidentiality of your password and account. You are also entirely responsible for any and all activities that occur under your account and we shall not be held liable for any claims, loss or damage resulting from a breach of the foregoing or any unauthorized use of your account.
15. Enquiries / Contact Us
This Policy applies to the collection, use, holding and processing of your Personal Information by us, which includes the following entities:
- GP Acoustics International Limited
- GP Acoustics GmbH
- GP Acoustics (China) Limited
- GP Acoustics (HK) Limited
- GP Acoustics (Taiwan) Limited
- GP Acoustics (UK) Limited
- GP Acoustics (US) Inc.
- KEF Japan Inc.
If you have any questions or complaints, or if you wish to access or correct your Personal Information or withdraw your consent to the use of your Personal Information held by us, or exercise any of your other rights as described in Section 1, please contact our Data Manager at data@kef.com. You may also contact us at:
Contact Information of KEF Entities
GP Acoustics International Limited
9/F, Building 12W, Hong Kong Science Park, New Territories, Hong Kong
GP Acoustics GmbH
Kruppstraße 82-100, 45145 Essen, Germany
GP Acoustics (UK) Limited
Eccleston Road, Tovil, Maidstone, Kent ME15 6QP, England, United Kingdom
GP Acoustics (US) Inc.
10 Timber Lane Marlboro, NJ 07746, USA
Tel.: 732-683-2356
GP Acoustics (China) Limited
深圳市福田区华富街道莲花一村社区皇岗路5001号深业上城（南区）T1栋14层
KEF Japan Inc.
1st floor, TFT Building East, 3-6-11 Ariake Koto-ku, Tokyo 135-0063 Japan
16. Regional Privacy Policy
Please refer to this Section of the Policy which applies in conjunction with the remaining Sections of the Policy if you are accessing and using KEF’s Environment within the following listed regions:
- the European Economic Area (“EEA”) and the United Kingdom
- the Republic of Korea
- the People’s Republic of China
- the United States of America, California
- Japan
16.1. Users from The EEA and the United Kingdom
Section 16.1 of the Policy only applies if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the EEA (including an EU Member State) and the United Kingdom. It supplements the information in the rest of the Policy, above.
GP Acoustics GmbH and/or GP Acoustics (UK) Limited are the data controller in respect of the processing of users’ Personal Information collected through KEF’s Environment.
16.1.1. Legal Basis for Processing of Personal Information
We describe in Section 3 what types of Personal Information we collect from you and describe the purposes for which we use and process that Personal Information. These together form the ground of processing. In additional, within this Section we set out the legal bases on which we rely for processing the Personal Information.
We rely on the following legal bases for processing Personal Information about you and when you access and use KEF’s Environment in the EEA (including an EU Member State) and the United Kingdom:
It Is In KEF’s Legitimate Interests To:
- Process your information such as gender, date of birth, location, company, job title, education, marital status and interests, when you choose to provide some or all of this information to us, in order to understand the demographics of users of our App and/or Website and to verify your account.
- Process your financial information (including account information and purchase activity) in order to fulfil your purchase orders and in order to prevent fraud and other illegal activities on our Website and/or App.
- Using information about your visits to, and usage of our Website and/or App (including your IP address, browsing preferences, device information, unique device identifiers, geolocation information and other information about your use of the Website and/or App), visits to KEF Physical Locations and information you provide us in surveys, marketing research questionnaires and/or focus groups in which you choose to participate in order to customize, enhance and optimize your experience on the Website and/or App and to help us to provide, maintain, optimize and improve the Website and/or App and improve your experience at the KEF Physical Locations.
- Monitor compliance with our terms and conditions of use on our Website and/or App and monitor any illegal activity on our Website and/or App.
- Performing a contract that we have entered into with you to provide you with the information, products or services that you have requested or purchased from us (or won, in the case of contests, competitions or promotions that you have chosen to enter), including fulfilling our maintenance services, and customer and/or technical support services and aftersales services obligations to you.
- Complying with applicable laws and regulations and KEF’s legal obligations such as accounting and tax requirements.
- Where necessary, we will procure your consent for processing certain Personal Information (for example, with respect to electronic marketing communications, as described in Section 5, above, and with respect to the use of geolocation data, if you choose to enable location tracking on your device, as described in Section 6, above). If we process your Personal Information on the basis of your consent, you may subsequently withdraw that consent at any time by the means indicated at the time consent is procured and/or through our contact information as described in Section 15. This does not affect the lawfulness of the processing that occurred on the basis of your earlier consent, before its withdrawal.
You are not required to provide KEF with Personal Information when you visit or use KEF’s Environment, but if you do not do so in the circumstances described above, we will not be able to provide you with certain information you request or with all of our products and services, and you will not be able to use all the features of our Website and/or App.
16.2. Users from Korea
Section 16.2 of the Policy only applies if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the Republic of Korea. It supplements the information in the rest of the Policy, above.
GP Acoustics International Limited is the data controller in respect of the processing of users’ Personal Information collected at KEF’s Environment.
16.2.1. Retention and Destruction of Personal Information
The following is a list of Personal Information that KEF may retain as fulfillment of obligations under applicable local laws and regulations. Personal Information will be retained and processed for the period and purpose as prescribed by these laws and regulations.
| Personal Information | Retention Period | Legal Basis |
|---|---|---|
| Records related to withdrawal of contracts or subscriptions, etc. | for 5 years | Act on Consumer Protection in Electronic Commerce, etc. |
| Record of Payment and Supply of Goods, etc. | for 5 years | Act on Consumer Protection in Electronic Commerce, etc. |
| Record concerning the handling of customer complaints or disputes; | for 3 years | Act on Consumer Protection in Electronic Commerce, etc. |
| Records on the Collection/Procession, Use, etc. of Credit Information | for 3 years | Act on the Use and Protection of Credit Information |
| Records of indications/advertising | for 6 months | Act on Consumer Protection in Electronic Commerce, etc. |
| User’s Internet log records/user’s access location tracking data and other communication facts verification data | for 3 months / for 12 months | Communication Secret Protection Act |
| Calculation of the period of exclusion from imposition of national taxes / Calculation of extinctive prescription such as national tax collection rights | for 10 years / for 5 years | Act on National Taxes |
Unless otherwise specified by the above local laws and regulations, KEF will destroy any Personal Information if the purpose of Personal Information collection is fulfilled, or if you have requested a withdrawal of our services and removal of your Personal Information. The entries of Personal Information stored in digital formats will be permanently deleted. Any physical media and records containing the Personal Information will either be shredded or incinerated.
In accordance with the Personal Information Protection Act, if you do not use any of KEF’s service (including but not limited to KEF website visiting, product purchasing, marketing activities interacting, mobile application usage etc.) for 1 year, KEF will separately store and manage your Personal Information. Notification of details of such separative handling will be provided prior to expiration of the 1-year requirement.
16.2.2. Outsourcing and Personal Information Transfers
Please note that your Personal Information may be transferred to KEF affiliates or subsidiaries operating in countries outside Korea, including but not limited to the EEA (including an EU Member State) the United Kingdom, the United States, Hong Kong, Singapore, Taiwan, Japan and Dubai. In addition, the service providers and other third parties with whom KEF may share information (as described in Section 9) may be based outside Korea. Data protection laws may or may not apply in jurisdictions outside Korea or may not be as stringent as those in Korea.
Data protection laws may or may not apply in jurisdictions outside Korea or may not be as stringent as those in Korea. In any case, KEF will comply with applicable laws and regulations and take all reasonable measures to ensure that your personal information is adequately protected during international transfers. For example, before transferring personal information across borders, we will seek your consent, and sign data protection clauses and data transfer agreements with overseas recipients.
In accordance with the related measures and regulations, you may withdraw your consent for international personal information transfer; however it may affect your access to corresponding services and products as KEF may no longer carry out such personal information transfer that is necessary for service and products provisioning. If you would like to withdraw your consent for international personal information transfer, you may send such requests or contact us through our contact information as described in Section 15.
The following is a list of local service providers and KEF affiliates or subsidiaries receiving Personal Information from KEF:
| Recipient Corporation | Personal Information | Purpose of Transfer | Usage / Retention Period |
|---|---|---|---|
| Sorishop https://www.sorishop.com/etc_html/company/privacy.html | Name, Email, Phone Number, Social media Account Details, Address, Survey Results, Invoice Number, Order Date | To perform product purchase, support and marketing activities for data subjects who submit their requests through website/APP | Until the purpose of service provision is achieved or user consent withdrawal. |
| KG INICIS https://www.inicis.com/privacy | Name, Email, Phone Number, Social media Account Details, Address, Invoice Number, Order Date | To perform product purchase | Until the purpose of service provision is achieved or user consent withdrawal. |
The following is a list of international service providers and KEF affiliates or subsidiaries receiving Personal Information from KEF:
| Recipient Corporation and Country | Personal Information | Purpose of Transfer | Transfer Date and Method | Usage / Retention Period |
|---|---|---|---|---|
| GP Acoustics International Limited Hong Kong https://hk.kef.com/pages/privacy-policy | Name, Email, Phone number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Financial and accounting purpose; meeting the purpose of processing as stated in Section 3. | At the time user provide consent for personal information collection and processing as specified under Section 3. | Until the purpose of service provision is achieved or user consent withdrawal. |
| Airable USA https://www.airtable.com/privacy#9-contact-us | IP address, MAC address | Provide “local radio stations” and “favorites” features to APP users | Continuous from the time user enables Airable service | Until user withdraw from this service or deletion of KEF APP. |
| Firebase USA https://firebase.google.com/support/privacy/dpo?hl=en | First name, last name, email address, social login id | Maintain user account | At the time user register for KEF ID | Until membership withdrawal |
| Provide user support | At the time user submit user support request | |||
| Perform APP problem diagnosis and improvement | At the time user submit APP diagnosis report | |||
| Salesforce USA https://www.salesforce.com/company/privacy/ | Name, Address, Email Address, Phone Number, Date of Birth, Gender, Purchase Record, Invoice Number, Order Date, Usage Records, Survey Results, Customer Feedbacks, Social Media Account, Digital Identifier such as an IP Address or a Cookie ID | Conduct sales related activities and/or offers our products for sale for the purpose of processing your purchase orders, sales delivery, conduct KEF’s marketing campaigns as well as any other purposes as specified under Section 3 above for and on KEF’s behalf. | At the time user provide consent for personal information collection and processing as specified under Section 3. | Until the purpose of service provision is achieved or user consent withdrawal. |
| Shopify Canada https://www.shopify.com/legal/privacy | Name, Address, Email Address, Phone Number, Date of Birth, Gender, Purchase Record, Invoice Number, Order Date, Usage Records, Survey Results, Customer Feedbacks,Social Media Account, Digital Identifier such as an IP Address or a Cookie ID | Conduct sales related activities and/or offers our products for sale for the purpose of processing your purchase orders, sales delivery, conduct KEF’s marketing campaigns as well as any other purposes as specified under Section 3 above for and on KEF’s behalf. | At the time user provide consent for personal information collection and processing as specified under Section 3. | Until the purpose of service provision is achieved or user consent withdrawal. |
| Obtain various types of non-personally identifiable demographics information; operate, maintain and/or improve the App and/or Website. | At the time user visit the App and/or Website and consent to the digital identifier data processing (or under legitimate interest for essential cookies data processing). | Until user withdraw consent to the digital identifier data processing. | ||
| Signifyd USA https://www.signifyd.com/privacy/ | Name, Email, Phone Number, Address, Credit Card Information, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Detect, prevent or address fraud or security issues; protect against harm to the rights, property or safety of KEF. | At the time user visit the App and/or Website and consent to the digital identifier data processing (or under legitimate interest for essential cookies data processing); During personal information provision for processing the purchase orders. | Until the purpose of service provision is achieved or user consent withdrawal. |
| Google USA https://support.google.com/policies/answer/9581826?hl=en | First name, last name, email address, social login id, Digital Identifier such as an IP Address or a Cookie ID | Enable social login. | At the time user register for social login. | Until user withdraw from social login |
| Obtain various types of non-personally identifiable demographics information; operate, maintain and/or improve the App and/or Website. | At the time user visit the App and/or Website and consent to the digital identifier data processing. | Until user withdraw consent to the digital identifier data processing. | ||
| Facebook USA https://www.facebook.com/privacy/policy?section_id=19-WhyAndHowWe | First name, last name, email address, social login id, Digital Identifier such as an IP Address or a Cookie ID | Enable social login. | At the time user register for social login. | Until user withdraw from social login |
| Obtain various types of non-personally identifiable demographics information; operate, maintain and/or improve the App and/or Website. | At the time user visit the App and/or Website and consent to the digital identifier data processing. | Until user withdraw consent to the digital identifier data processing. | ||
| Linkedin USA https://www.linkedin.com/legal/privacy-policy | Digital Identifier such as an IP Address or a Cookie ID | Obtain various types of non-personally identifiable demographics information; operate, maintain and/or improve the App and/or Website. | At the time user visit the App and/or Website and consent to the digital identifier data processing. | Until user withdraw consent to the digital identifier data processing. |
| Twitter USA https://twitter.com/en/privacy | Digital Identifier such as an IP Address or a Cookie ID | Obtain various types of non-personally identifiable demographics information; operate, maintain and/or improve the App and/or Website. | At the time user visit the App and/or Website and consent to the digital identifier data processing. | Until user withdraw consent to the digital identifier data processing. |
| Mavenoid Sweden https://www.mavenoid.com/en/privacy/privacy-policy | Name, Email, Phone Number, Address, Invoice Number, Order Date, Video, Photo | Provide customer support services to address customer’s enquiry. | At the time user visit the App and/or Website and consent to the cookies | Until user consent withdrawal. |
*Remarks: KEF with the best effort will continuously review and update the above lists to provide the latest information on data transfer. Change of service provider/ third party may occur with the consideration of information security, data subject’s legitimate interest and compliance on regulation requirement.
16.3. Users from China
Section 16.3 of the Policy only applies if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the People’s Republic of China. It supplements the information in the rest of the Policy, above.
GP Acoustics (China) Limited is the data controller in respect of the processing of users’ Personal Information collected at KEF’s Environment.
16.3.1. Personal Information Collected From Third Party
In addition to the Section 3.2, following personal information is also collected from third parties:
| Category | Personal Information | Collection Channels | Purpose | Justification |
|---|---|---|---|---|
| Membership Management and Online Purchase | Name, Email, Date of Birth, Phone Number, Gender, User Profile Image, UnionID, OpenID, Residence Address, Purchase Record, Usage Records, Shipping Address, Invoice Number, Order Date | WeChat WeChat Mini Program – Youzan JINGdigital | Register, verify and manage your account on the APP. Compile, maintain and update our database of users on the App and/or Website. | – Performance of a Contract – Consent |
| WeChat Mini Program – Youzan | Processing your purchase orders and contacting you regarding your purchase orders if necessary, as well as arranging delivery of the purchased goods. | – Performance of a Contract |
16.3.2. List of Third Party
As described in Section 9, KEF may transfer your Personal Information from/to below list of third parties:
| Category | Third Party | Personal Information | Purpose |
|---|---|---|---|
| KEF’s Affiliates or Subsidiaries | GP Acoustics International Limited https://hk.kef.com/pages/privacy-policy | Name, Email, Phone number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Financial and accounting purpose; meeting the purpose of processing as stated in Section 3. |
| E-commerce Platform and Technology Provider | WeChat Mini Program – Youzan https://www.youzan.com/intro/rule/detail?alias=132atyi19&pageType=rules Shopify https://zh.shopify.com/legal/privacy Salesforce https://www.salesforce.com/company/privacy/ JINGdigital https://www.jingdigital.com/%E9%9A%90%E7%A7%81%E6%94%BF%E7%AD%96/ | Name, Address, Email Address, Phone Number, Social Media Account, Digital Identifier such as an IP Address or a Cookie ID. | Conduct sales related activities and/or offers our products for sale for the purpose of processing your purchase orders, sales delivery, conduct KEF’s marketing campaigns as well as any other purposes as specified under Section 3 above for and on KEF’s behalf. |
| Installment and Payment | Jingdong https://in.m.jd.com/help/app/private_policy.html TMall https://terms.alicdn.com/legal-agreement/terms/suit_bu1_tmall/suit_bu1_tmall201801031144_60809.html?spm=875.7931836.0.0.7a7242651z2g4z WeChat Mini Program – Youzan https://www.youzan.com/intro/rule/detail?alias=132atyi19&pageType=rules | Name, Email, Phone Number, Address, Credit Card Information, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Provide payment settlement with installment options through service provide to settle purchase order. |
| Third Party Warehouse and Logistics | Huilong International Logistics (Shenzhen) Co., Ltd. https://www.5684.com/homepage/about/4824 Guangzhou Blackfish Software Tech. Co., Ltd. http://www.e-blackfish.com/#page6 | Name, Email, Phone Number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Arrange delivery of the goods you have purchased from KEF’s Environment. |
| Social Media Platform | WeChat https://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy https://weibo.com/signup/v5/privacy Xiaohongshu https://www.xiaohongshu.com/privacy | Social Media Account ID, Digital Identifier such as an IP Address or a Cookie ID. | Connect your KEF membership account or App with such Third-Party Services for login. |
| Outsourced Customer Service | Touch Point Information Technology Co, Ltd http://www.touch-tech.com.cn/about/ | Name, Email, Phone Number, Address, Invoice Number, Order Date | Provide customer support services to address customer’s enquiry. |
| Authorized Dealer | Refer to “Find a Retailer” for more information. https://www.kef.cn/pages/store-locator | Name, Email, Phone Number, Address, Invoice Number, Order Date | Provide sales and aftersales services for KEF’s products. |
| Distributors | Refer to “Find a Retailer” for more information. https://www.kef.cn/pages/store-locator | Name, Email, Phone Number, Address, Invoice Number, Order Date | Manage product supply and distribution of KEF’s products, and provide customer support services. |
| Marketing Agencies and Consultant | Hill & Knowlton (China) Public Relations Co., Ltd. https://www.hkstrategies.com/en/privacy-policy/ Precision Digital Marketing Ltd. https://www.precision-site.com/ Shanghai Jiuhe Media Co., Ltd. http://www.yinlimedia.com/ INLY Communication Co., Ltd http://www.yinlimedia.com/ EternityX Marketing Technology Limited https://www.eternityx.com/privacy/ | Name, Email, Phone Number, Social Media Account Details, Date of Birth, Gender, Age, Address, Survey Results | Conduct KEF’s marketing campaigns; Review, improve and strengthen our marketing strategies, advertisement, promotional materials and content of KEF’s Environment. |
*Remarks: KEF with the best effort will continuously review and update the above list to provide the latest information on data transfer. Change of service provider/ third party may occur with the consideration of information security, data subject’s legitimate interest and compliance on regulation requirement.
16.3.3. International Transfer And Location Of Data Processing
Under most circumstances, Personal Information collected and generated during KEF’s operation in China will be stored and processed inside China Region. However, KEF is an international company and we have other KEF affiliates or subsidiaries, service providers and other third parties (as described in Section 13) around the world. Therefore, the Personal Information we collect may be transferred to and stored in countries or regions outside of China. International transfers of personal information involve the countries in which KEF affiliates or subsidiaries, service providers and other third parties are located.
We will comply with applicable laws and regulations and take all reasonable measures to ensure that your personal information is adequately protected during international transfers. For example, before transferring personal information across borders, we will seek your consent, and sign data protection clauses and data transfer agreements with overseas recipients. In any case, if you would like to exercise your rights against an overseas recipient (such as those described in Section 1), you should refer to the privacy policy of the respective overseas recipient to make your request.
In accordance with the related measures and regulations, if standard contract is signed as lawful means for cross-border data transfer, you as the data subject will become the third party beneficiary of the standard contract unless we receive any objection from you.
The list of overseas recipients is as follows:
| Recipient Corporation and Country | Personal Information | Purpose of Transfer | Transfer Date and Method | Usage / Retention Period |
|---|---|---|---|---|
| GP Acoustics International Limited Hong Kong https://hk.kef.com/pages/privacy-policy | Name, Email, Phone number, Address, Invoice Number, Order Date, Digital Identifier such as an IP Address or a Cookie ID. | Financial and accounting purpose; meeting the purpose of processing as stated in Section 3. | At the time user provide consent for personal information collection and processing as specified under Section 3. | Until the purpose of service provision is achieved or user consent withdrawal. |
| Shopify Canada https://www.shopify.com/legal/privacy | Name, Address, Email Address, Phone Number, Product ID, Retailer, Purchase Price, Device Information, Digital Identifier such as an IP Address or a Cookie ID | Conduct customer service and relationship management, enhance website experience, provide product support and enhancement, conduct KEF’s marketing campaigns; as well as any other purposes as specified under Section 3 above for and on KEF’s behalf. | At the time user provide consent for personal information collection and processing as specified under Section 3. | Until the purpose of service provision is achieved or user consent withdrawal. |
| Salesforce USA https://www.salesforce.com/company/privacy/ | Name, Address, Email Address, Phone Number, Date of Birth, Gender, Purchase Record, Invoice Number, Order Date, Usage Records, Survey Results, Customer Feedbacks, Social Media Account, Digital Identifier such as an IP Address or a Cookie ID | Conduct customer service and relationship management, enhance website experience, provide product support and enhancement, conduct KEF’s marketing campaigns; as well as any other purposes as specified under Section 3 above for and on KEF’s behalf. | At the time user provide consent for personal information collection and processing as specified under Section 3. | Until the purpose of service provision is achieved; or membership withdrawal; or user consent withdrawal. |
*Remarks: KEF with the best effort will continuously review and update the above lists to provide the latest information on data transfer. Change of service provider/ third party may occur with the consideration of information security, data subject’s legitimate interest and compliance on regulation requirement.
16.4. Users From United States Of America, California
Section 16.4 of the Policy only applies if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the United States of America, California. It supplements the information in the rest of the Policy, above.
GP Acoustics (US) Inc. is the data controller in respect of the processing of users’ Personal Information collected at KEF’s Environment.
16.4.1. Your Data Subject Right
In addition to your data subject right as stated in Section 1, California residents are also entitled for the following rights under the privacy regulations of California, e.g. California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”):
- Right to Opt-Out of Sale or Sharing of Personal Information: We do not sell your Personal Information. Although with the statutory definition of the terms “sell or share of Personal Information” under CCPA or CPRA is broad, it may include the use of interest-based advertising via cookies and similar technologies about your online activity. Meanwhile, we do share identifiers such as cookies and the advertising identifier to third-party as to show ads that are targeted to your interests, and you can opt out or manage your website cookies preference at any time by clicking the “Do Not Sell or Share My Personal Information” link on our website footer, and refer to Section 7 and our Cookies Policy for more information.
- Right to Request Information on Data Disclosure for Third Parties’ Direct Marketing Purposes: You can request information regarding the Personal Information disclosure to third parties for the third parties’ direct marketing purposes.
We will not discriminate against you if you choose to exercise your rights under applicable privacy regulations. You may send such requests or contact us through our contact information as described in Section 15.
16.4.2. Notice Of Financial Incentive
Under the CCPA or CPRA, KEF is allowed to offer financial incentives to you for any Personal Information collection and processing if such financial incentives are reasonably related to the value of provided Personal Information. Our good-faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.
For example, we provide discounts or benefits to members of our KEF membership program, and subscribers of our newsletters, i.e. KEF Updates. And in some cases, we offer discounts or benefits in our marketing campaigns, such as limited-time sweepstakes and contests. When you participate in our membership program or other financial incentives we offer, we collect Personal Information from you as described in Section 3, such as your name, email address, phone number, date of birth, and gender.
Your participation to the financial incentives program will be subject to applicable terms and conditions, which we will provide to you when you sign up for the program. Participation in our financial incentive programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. To unsubscribe or cancel your participation in any program, you can contact us through methods as described in Section 15.
16.5. Users from Japan
Section 16.5 of the Policy only applies if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in Japan. It supplements the information in the rest of the Policy, above.
KEF Japan Inc. is the data controller in respect of the processing of users’ Personal Information collected at KEF’s Environment.
16.5.1. Your Data Subject Right
In addition to your data subject right as stated in Section 1, Japan residents are also entitled for the following rights under the privacy regulations of Japan, e.g. Act on the Protection of Personal Information (“APPI”):
- Disclosure of record for third-party provision: You have right to access to the records of Personal Information provision to third party (if any).
You may send such requests or contact us through our contact information as described in Section 15.
16.5.2. International Transfer
KEF may process your Personal Information globally and perform international transfer as described in Section 13. For overview of the legal system regarding the protection of Personal Information in such relevant country, please refer to https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku as reference.