1. What Personal Data We Collect

We process the following Personal Data about you for the purposes listed in paragraph 3 below:

• - your identification data such as your full name, date of birth, email address and phone number;
• - data relating to your user account;
• - data relating to your child, such as your child’s name, your child’s date of birth,- your child’s gender as well as child specific data such as child potty accidents, potty event descriptions, feedings, sleep data, use of diapers, growth data to be registered in a diary at your benefit;
• - data relating to your device, such as -Device ID (Desktop, Tablet or Mobile) and your IP address;
• - user-generated content, social media postings, social media user name or ID, or social media profile picture;
• - Feedback manually entered by parents in tutorial and coaching checklist.

With specific reference to data relating to your child - due to the features of the website which is created in order to provide you with, among others, a complete diary of your child information –also special categories of personal data, such as your child health tracker data (symptoms, temperature, medications, illness data) might be included in the website. Such data, which are encrypted in order to guarantee their security, are included, among others, in the website as long as you decide to insert such information. In order to process such data it is necessary to obtain your explicit consent. If no consent is provided, please do not include any special category of personal data within the website.

Finally, with regard to the data listed above, some of the Personal Data involved in the process refer to your child, which is under 18 years of age. Creating your account you represent and guarantee that you are at least 18 years old and the parent of the child or the guardian exercising parental responsibility over the child.

2. The Purposes for which We Process Your Personal Data

We process your Personal Data for the following purposes:

• a) to use the website and its functionalities and services, including the possibility to access any information as available in your account and to provide you with information, products and services as requested by you;
• b)to administer our website and help improve our products and services;
• c)to provide customer support and technical assistance;



(the purposes referred to in the letters a) and b) above are jointly defined as the "Contractual Purposes");

• d)to comply with applicable laws and regulations (including antifraud laws, money laundering laws) and/or respond to request from public and government authorities;



(the purpose referred to in letter d) is defined as “Purpose of Law”);

• e)with your prior consent, to deliver direct marketing communications concerning products and services of Kimberly-Clark (e.g., sending of advertising materials, market researches and market research to allow us to assess trends and the effectiveness or our advertising and marketing campaigns). The communications, may be sent by both automated (e.g., SMS, MMS, calling systems, email, social media messages and web applications) and traditional (e.g., calls by human operators) means of contact;
• f)with your prior consent, the delivery of marketing communications customized on your interests and needs by means of the channels of communication set out under letter e) above;



(the purposes referred to in letters e) and f) above are jointly defined as “Marketing Purposes”);

• g)if you granted the consent to the delivery of marketing communications referred under letter e) above, to perform non-invasive analysis based, among others, on the categories of being state of motherhood (pregnancy & new mom), being first or second mom and babies age, or month of pregnancy.
• h)anonymize and/or aggregate personal data for research and statistical purposes;
• i)to complete a potential merger, sale of assets or transfer of all or a material part of its business, by disclosing and transferring your personal data to the third party or parties involved in the transaction as part of the transaction;



(the purposes referred to in letters g) and h) are defined as “Legitimate Interest Purpose”).

3. The Legal basis for the Processing of Your Personal Data

Data protection law requires us to have a legal ground before processing any Personal Data about you.

The processing of your personal data is necessary with regard to the Contractual Purposes and Purpose of Law as it is essential (i) for the performance of the contract regarding the provision of the services as made available within the website and (ii) in order to comply with provisions as provided by the applicable laws. Should you not provide your personal data for the above mentioned purposes, Kimberly-Clark will not be able to provide you with the services as available in the website.

The data processing with regard to the Marketing Purposes is based on your prior consent. Such data processing is not mandatory however should you refuse to provide the relevant consent you will not receive marketing communications as per section 2 letters e) and f) above. In any case, you can withdraw your consents at any time through the modalities as per this Privacy Policy.

Finally, the processing of your personal data with regard to the Legitimate Interest Purposes as per section 2 letters g) is carried out pursuant to article 6, letter f) of the EU General Data Protection Regulation No. 679/2016 (the "Privacy Regulation"), for the pursuit of Kimberly-Clark legitimate interest, which is adequately balanced with your interest since the data processing is performed within the limits strictly necessary to perform such activities.

This data processing activity with regard to the Legitimate Interest Purposes is not mandatory and you can object to the data processing at any time through the modalities as per Privacy Policy, unless Kimberly-Clark demonstrates the existence of prevailing legitimate reasons or in order to protects its rights in compliance with article 21 of the Privacy Regulation.

4. Who We Share Your Personal Data With

For the above mentioned purposes, we may share information about you with third parties in certain circumstances specifically in the following situations:

- Sharing Your Information with Service Providers;

We may share information with companies or individuals, if necessary, that provide us with services in their capacity of data processors. These services may include, among other things, helping us in the field of marketing, technology, accounting, administrative, legal, insurance, IT matters.

- Law Enforcement and Legal Process;

We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity (including, notably, when we receive a fair, reasonable and legal request from a law enforcement or regulatory body). In addition, we may release your information to law enforcement agencies if we determine that either you have violated our policies, or the release of your information may protect the rights, property, or safety of Kimberly-Clark, or another person.

- Sharing Your Information as Permitted by Law;

We may share your information with others as required by, or permitted by, law. This may include sharing your information with government entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights and/or to protect the property or safety of our customers or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction), to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us.

- Blogs, Online Postings, and Testimonials;

We may decide to allow users to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public. Information that you provide in these areas may be read, collected, and used by others who access them.

- Business Transaction;

In the event that we, or any portion of our assets, are acquired or we undertake a business or asset acquisition or prospective acquisition process, your information may be transferred to the acquiring company or other entity surviving such a transaction.

5. Managing Your Privacy Through Your User Profile

Apart from the rights as indicated in section 9 below, we provide you with the ability to exercise certain controls and choices regarding how we collect, use and share your Personal Data. By changing your User Profile or contacting us as described within this Privacy Notice, you may do the following: (1) you may correct, update and delete your registration account; (2) you may change your choices for subscriptions and alerts; (3) you may change your preferences as to the receipt of offers and promotions for our products and services, or products and services that we think may be of interest to you; (4) you may change your preferences whether we share your contact information with partners so they can send you offers and promotions about their products and services.

6. Transfer of Personal Data abroad

Your Personal Data may be transferred outside of the country from which it was originally provided and may be shared with our trusted third parties located in jurisdictions outside European Economic Area (EEA) and the UK which have no data protection laws or laws that are less strict compared with those in Europe, specifically in the US. Whenever we transfer Personal Data outside of the EEA or the UK, we take legally required steps to make sure that adequate safeguards are in place to protect your Personal Data and to make sure it is treated securely and in accordance with this Privacy Notice such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the Privacy Regulation . If you are located in the EEA or the UK, you can contact us +44 1737 736060 for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances.

7. Data Retention

We retain your Personal Data for as long as necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Notice. In any case the following retention periods will apply to the processing of your personal data for the purposes indicated below:

• i.data collected for Contractual Purposes and for Legitimate Interest Purposes as per Section 3, letter h) is retained during the provision of the services made available through the website plus a period of 10 years after the termination or withdrawal, except when the retention of the data is necessary to respond or to file a legal actions, upon request of the competent authorities or in compliance with the applicable laws;
• ii.data collected for Marketing Purposes as per Section 2, letter e) and for Legitimate Interest Purposes as per Section 2, letter g) of this Privacy Notice is retained for a period of 24 months;
• iii.data collected for Marketing Purposes as per Section 2 letter f) of this Privacy Notice is retained for a period of 12 months.

8. Your Rights

Data protection law gives rights to individuals in respect of Personal Data that organisations hold about them. In particular you can, at any given time, exercise the following rights:

• a)to obtain from Kimberly-Clark confirmation of the existence of personal data and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;
• b)request the erasure, anonymisation or restriction of the processing of data processed in breach of the applicable laws;
• c)object in whole or in part, on legitimate grounds, to the processing of the data;
• d)to withdraw the consent to the processing of the data (if and to the extent such a consent is necessary).

In addition to the above you will also have the right, in any given moment, to:

• e)request Kimberly-Clark to limit the processing of your personal where:
• •you contest the accuracy of the personal data until Kimberly-Clark has taken sufficient steps to correct or verify its accuracy;
• •the processing is unlawful but you do not want us to erase the data;
• •Kimberly-Clark no longer needs the your data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
• •you objected to processing justified on legitimate interests, pending verification as to whether Kimberly-Clark has compelling legitimate grounds to continue processing.
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• f) request the erasure of the data;
• g)receive an electronic copy of the data, if you would like to port data to yourself or a different provider, when Kimberly-Clark is relying upon your consent or the fact that the processing is necessary for the provision of the services and the data is processed by automatic means; and
• h)lodge a complaint with the relevant data protection supervisory authority.
• i)With regard to marketing communications, apart from revoking you consent if you decide that you do not want to receive commercial emails from us, you can also “opt-out” from receiving such emails by clicking on the “unsubscribe” link provided at the bottom of every commercial email.
  
  If you would like to exercise your rights, please contact us using the contact information set out in paragraph 10 below. Please note that requests to exercise data protection rights will be assessed by Kimberly-Clark on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.

10. Changes to the Privacy Notice

We may modify or amend this Privacy Notice at any time by posting the revised Privacy Notice in our website. We recommend that you review our Privacy Notice every time you submit information to us or place an order.