KIKO USA INC: PRIVACY STATEMENT

Last Updated: September 10th, 2026

1. Introduction and Identity of the Data Controller

This Privacy Statement ("Statement") describes how KIKO USA Inc. ("KIKO USA", "we", "us", or "our") collects, uses, discloses, and otherwise processes personal data in connection with the KIKO Milano U.S. e-commerce website and U.S. stores (collectively, the "U.S. Channels").

KIKO USA Inc. is the sole data controller for all personal data collected through the U.S. Channels.   If you are a customer of any KIKO website or store other than the U.S. Channels, including any European website or store, the relevant KIKO entity for that channel will act as data controller under the laws applicable to that channel. The U.S. website is directed exclusively at individuals located in the United States. Individuals located in the European Union or European Economic Area who wish to purchase KIKO products should visit www.kikocosmetics.com/it-it/ . Processing of personal data of EU/EEA-located individuals is carried out by KIKO S.p.A. in accordance with the General Data Protection Regulation.

To contact us regarding this Statement or to exercise your privacy rights, please use the contact information provided in Section 14 of this Statement.

2. Scope of This Statement

This Statement applies to personal data collected through:

·         the KIKO Milano U.S. e-commerce website (the "Website"); and

·         KIKO Milano U.S. physical stores ("U.S. Stores"), in the limited circumstances in which personal data is collected in-store (for example, where a customer requests a home delivery or an invoice).

This Statement does not apply to any KIKO website, application, or store other than the U.S. Channels, including any European website or store. Customers who purchase products or create an account through any other KIKO channel, even if they have selected the United States as their preferred country, will be subject to the privacy notice of the relevant KIKO entity operating that channel.

By using our Website or U.S. Channels, you acknowledge that your personal data will be handled as described in this Statement. 

3. Personal Data We Collect

We collect personal data directly from you, automatically through your use of the Website, and from other sources. To the extent permitted by applicable law, we may combine information collected from multiple sources.

3.1 Personal Data We Collect Directly From You

While the personal data we collect varies depending on your use of the Website and your interactions with us, we may collect the following personal data directly from you:

·         Contact Information. When you contact us, we collect your name, email address, phone number, the nature of your inquiry, and any other information you choose to provide.

·         Account Information. When you register for an account, we collect your name, date of birth, gender, email address, password, and other information used to access your account.

·         Purchases and Payments. When you make purchases through the Website or in-store (where applicable), we collect payment information, name, billing address, and shipping address.

·         Communications and Interactions. When you contact us by email, phone, or otherwise, we collect and maintain a record of your contact details, the content of your communications, and our responses.

·         Responses and Feedback. If you participate in surveys or questionnaires, we collect your responses and feedback, including user satisfaction information and any other information you choose to provide.

·         Marketing and Promotions. If you agree to receive marketing communications from us, we collect your email address, name, phone number, and preferences. For SMS marketing, we additionally collect your mobile telephone number and consent record, as described in Section 7.

·         Preferences. We may collect information about your preferences, including communications preferences.

·         Product Reviews. If you purchase a KIKO product through the Website, we may invite you to submit a written review and, optionally, upload an image of the product purchased. When you submit a review, we collect your name (or username), email address, the text of your review, and any images you upload, as well as browser-generated information and order reference information used to verify your purchase.

·         In-Store Data (Limited Circumstances). In U.S. Stores, personal data is collected only in limited circumstances, such as when you request home delivery of products (in which case we collect your name, delivery address, email, and phone number) or request an invoice (in which case we collect your name, address, and tax identification information if required).

3.2 Personal Data We Collect Automatically

We and our third-party providers automatically collect certain personal data when you use the Website, including through cookies and similar tracking technologies. Please see Section 8 (Cookies and Other Tracking Mechanisms) and our Cookie Statement, available at https://us.kikocosmetics.com/pages/cookie-policy, for further detail. The personal data we may collect automatically includes:

·         Device and Browsing Information. IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique device identifier, internet service provider, referring and exiting URLs, clickstream data, and similar information.

·         Activities and Usage. Links clicked, searches, features used, items viewed, time spent within the Website, interactions with us within the Website, and other activity and usage information.

·         Location Information. We may derive general location information from your IP address. If you enable location-based sharing through your device settings, we may collect more precise location information to provide content relevant to your location. You may disable location sharing through your device settings.

3.3 Personal Data We Collect From Other Sources

We may collect and receive personal data from business partners, data analytics providers, internet service providers, operating systems and platforms, public databases, and service providers who assist us in operating our business.

4. How We Use Personal Data

We collect, use, and otherwise process personal data for the following purposes:

·         Website and Account Operations. To allow you to create and maintain your account, provide and operate the Website, communicate with you about your use of the Website, respond to your inquiries, and run our day-to-day operations.

·         Purchases, Payments, and Fulfillment. To process your orders, process payments, arrange delivery or home shipment of products, issue invoices and receipts, and manage returns and exchanges.

·         Direct Marketing: Email. To send you promotional emails, newsletters, and commercial communications about KIKO products, events, and offers. Where you are an existing customer, we may send you marketing emails about similar products and services to those you have previously purchased. You may opt out at any time as described in Section 9.

·         Direct Marketing: SMS. To send you promotional text messages (SMS) about KIKO products, events, and offers, where you have provided your prior express written consent where required by applicable law. Message and data rates may apply. You may opt out of SMS marketing at any time by replying STOP to any marketing message or as otherwise described in Section 9.

·         Product Reviews. To invite you to submit a review of products you have purchased, to verify the authenticity of reviews, and to publish your review (including your name or username and any images you submit) on our Website.

·         Customer Service and Support. To respond to inquiries, handle complaints, and provide customer support in connection with your purchases and use of the Website.

·         Analytics and Improvement. To understand how users access and use the Website; for research and analytical purposes; to improve and develop our Website and its features; and for internal quality control and training.

·         Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.

·         Interactive Website Features. To enable interactive features of the Website, including virtual try-on tools and similar features.

·         Legal Obligations. To comply with applicable federal, state, and local legal and regulatory obligations, including tax, accounting, and record-keeping requirements.

·         Legal Claims. To establish, exercise, and defend legal rights and claims; to respond to subpoenas, court orders, and other legal process; and as part of investigations or requests from law enforcement or governmental authorities.

·         Security and Fraud Prevention. To protect the security and integrity of our Website and business operations; to detect, prevent, and investigate fraud, unauthorized activities and access, and other misuse; and where necessary to investigate, prevent, or act regarding illegal activities or potential threats to safety.

·         Auditing, Reporting, and Internal Operations. To conduct financial, tax, and accounting audits; assessments of our operations, privacy, security, and financial controls; risk and compliance reviews; and general business, accounting, record-keeping, and legal functions.

·         Business Transactions. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and to administer related business and legal functions.

5. How We Disclose Personal Data

We may disclose the personal data we collect for the purposes described above and as follows:

·         Affiliates and Group Companies. We may disclose personal data to our corporate affiliates, including KIKO S.p.A. and other entities within the KIKO group, where they are acting as our service providers (for example, providing accounting, logistics, IT infrastructure, or other operational support services) pursuant to a Data Processing Agreement.

·         Vendors and Service Providers. We disclose personal data to third-party service providers who perform functions on our behalf, such as IT and website hosting, payment processing, shipping and fulfillment, customer support, email delivery, SMS marketing, data storage, data analytics and processing, auditors, consultants, and legal counsel. These service providers are contractually required to use personal data only as directed by us and in accordance with applicable law.

·         Marketing and Analytics Providers. We may disclose your personal data, including device and browsing information and activities and usage information, to marketing and advertising networks, data analytics providers, and other companies that provide marketing or analytics services on our behalf. For more information, see Section 8 (Cookies and Other Tracking Mechanisms).

·         Social Media Platforms. Our Website incorporates tools associated with social media platforms (including Meta/Facebook, TikTok, Pinterest, Snapchat, and similar platforms) that may collect information about your interactions with our Website. Where such platforms process personal data in connection with our Website, they may act as independent data controllers with respect to their own processing. Please consult the relevant platform's privacy Statement for further information.

·         Product Review Platforms. If you submit a product review, your review (including your name or username and any accompanying images) may be published on our Website and may be shared with our review management service provider.

·         Business Transfers. If KIKO USA or its affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets may be transferred to another company, we may disclose or transfer personal data in connection with such transaction, including to lenders, auditors, and third-party advisors.

·         Compliance and Legal Obligations. We may disclose personal data to comply with our legal and regulatory obligations and to respond to legal process, including in response to subpoenas, court orders, and lawful requests from law enforcement or governmental authorities, including to meet national security or law enforcement requirements.

·         Security and Protection of Rights. We may disclose personal data where necessary to protect us, our rights and property, or the rights, property, and safety of others; in connection with litigation or legal proceedings; and for our internal accounting, auditing, compliance, record-keeping, and legal functions.

·         Aggregate and De-identified Information. We may use, disclose, and otherwise process aggregate and de-identified information related to our business and the Website for quality control, analytics, research, development, and other purposes. We agree not to re-identify de-identified data except as permitted by applicable law.

·         Other Disclosures. We may disclose personal data in other ways not described above, but will notify you and, if required by applicable law, obtain your consent.

6. Disclosure of Personal Data to U.S. Social Media Platforms

Our Website uses pixels and similar technologies provided by social media platforms including Meta (Facebook/Instagram), TikTok, Pinterest, and Snapchat. These technologies may transmit information about your use of the Website (including IP address, browser type, and browsing activity) directly to the platform's servers when you interact with our Website. These platforms may use this information in accordance with their own privacy policies, including for advertising and analytics purposes.

For more information about how these platforms process personal data, please consult their privacy policies:

·         Meta (Facebook/Instagram): https://www.facebook.com/privacy/Statement/

·         TikTok: https://www.tiktok.com/legal/page/us/privacy-Statement/en

·         Pinterest: https://Statement.pinterest.com/en/privacy-Statement

·         Snapchat: https://values.snap.com/privacy/privacy-Statement

·         Google: https://policies.google.com/privacy?hl=en-US

7. Direct Marketing

7.1 Email Marketing

We may send promotional emails and newsletters to customers who have provided their email address in connection with a purchase or who have separately subscribed to our marketing communications. All marketing emails will include an option to unsubscribe. You may opt out of marketing emails at any time by using the unsubscribe link in any marketing email or by contacting us at privacykikous@kikocosmetics.com. Opting out of marketing emails will not affect transactional or service-related communications relating to your orders or account.

7.2 SMS / Text Message Marketing

With your affirmative consent, we may send you SMS/Text messages from us to the mobile number you provide. By providing your consent, you agree to receive such messages and acknowledge the following:

·         Purpose and Frequency. Messages may include marketing communications, promotions, sales, and general information related to us. Frequency varies based on your interactions and our campaigns.

·         Message and Data Rates. Standard carrier messaging and data rates may apply.

·         Help and Unsubscribe. Use HELP for assistance or STOP to unsubscribe at any time. After you opt-out, you will receive one final confirmation message, and no further texts will be sent.

·         Carrier Liability. Mobile carriers are not liable for delayed or undelivered messages.

·         Data Sharing. We do not sell, rent, or share your mobile number or consent/opt-in information to third parties for their own marketing purposes. We may disclose your information to service providers acting on our behalf to deliver messages to you.

 

8. Cookies and Other Tracking Mechanisms

We and our third-party providers use cookies and similar tracking technologies to automatically collect information about your browsing activity, device type, and interactions within our Website. We use this information to analyze how you access and use the Website, identify and resolve technical issues, assess and improve the performance of the Website, serve marketing and advertising content, and to personalize content.

For detailed information about the cookies and tracking technologies we use, including the specific cookies deployed, their purposes, and retention periods, please see our Cookie Statement, available at https://us.kikocosmetics.com/pages/cookie-policy

·         Cookies. Cookies are alphanumeric identifiers stored on your device. Some cookies enable core website functionality; others support security and performance of the Website; and others enable us to track activity and usage data.

·         Third-Party Analytics. We use third-party analytics tools, such as Google Analytics, to evaluate usage of our Website. These tools use cookies and similar technologies to collect data. For more information, see Google's Privacy Statement at https://policies.google.com/privacy and the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout.

·         Advertising and Targeting Technologies. We work with third-party advertising networks, analytics providers, and marketing partners to personalize content and display advertising within our Website and on third-party sites. These partners may use cookies, pixel tags, and other tools to collect browsing and activity information. Under applicable state privacy laws, certain disclosures of personal data to these third parties may constitute a "sale" or "sharing" of personal data or use of personal data for "targeted advertising." You may opt out of these disclosures as described in Section 9 and in our Cookie Statement.

o    Global Privacy Control (GPC). If our Website detects that your browser or device is transmitting an opt-out preference signal, such as a Global Privacy Control (GPC) signal, we will treat that signal as a request to opt out of the sale, sharing, or use for targeted advertising of your personal data collected through cookies on that browser or device. If you visit our Website from a different device or browser, or if you clear your cookies, you will need to set your opt-out preference again for that device or browser.

·         Do Not Track. Our Website does not currently respond to "Do-Not-Track" signals. You may, however, manage your preferences through the cookie settings described in our Cookie Statement.

 

9. Your Privacy Choices

We provide the following ways for you to manage your personal data and privacy preferences:

·         Cookie and Tracking Preferences. You may manage your cookie preferences, including opting out of analytical and advertising cookies, through the "https://us.kikocosmetics.com/pages/data-sharing-opt-out link in the footer of our Website or through the cookie settings tool on the Website.

·         Opt-Out of Sale/Sharing/Targeted Advertising. "You may opt out of the sale, sharing, or use for targeted advertising of your personal data by clicking the 'Reject All' link in the cookie banner, clicking 'Reject Non-Functional' in Your Privacy Choices located in the footer of our Website, by using a Global Privacy Control (GPC) signal (see Section 8), or by submitting a request using the contact information in Section 14.

·         Marketing Email Opt-Out. You may opt out of marketing emails by clicking the unsubscribe link in any marketing email we send you, by logging in to your account and adjusting your communications preferences, or by contacting us at privacykikous@kikocosmetics.com.

·         SMS Marketing Opt-Out. You may opt out of SMS marketing messages at any time by replying STOP to any marketing text message or by contacting us at privacykikous@kikocosmetics.com.

·         Account and Profile Information. If you have an account with us, you may access, review, and update your account and profile information, including your name, email address, contact information, and preferences, by logging in and accessing the relevant section of your account.

·         Industry Ad Choice Programs. You may obtain information about targeted advertising from participating third-party ad networks at www.aboutads.info/choices (Digital Advertising Alliance). Opting out of participating networks does not opt you out of all advertising; you may continue to receive generic or contextual ads.

10. Children's Information

Our Website is not directed to children under the age of 13, and we do not knowingly collect personal data from children under 13. If you are a parent or legal guardian and believe we have collected personal data from your child in violation of applicable law, please contact us using the contact information in Section 14. We will take appropriate steps to investigate and, if confirmed, delete such information.

11. External Links and Third-Party Features

Our Website may contain links to third-party websites or features. Access to and use of those websites or features is governed by the privacy policies of the relevant third parties and not by this Statement. We are not responsible for the information practices of third parties, including their collection of your personal data. Please review the privacy policies of any third-party websites before providing personal data to them.

12. Security

We have implemented technical and organizational safeguards designed to protect personal data from unauthorized access, disclosure, alteration, loss, or destruction. However, no data security measure can guarantee complete security. Please contact us immediately using the information in Section 14 if you have reason to believe that your interaction with us is no longer secure.

13. Retention of Personal Data

We retain personal data for as long as needed or permitted in light of the purpose for which it was collected and in accordance with applicable law. In determining how long to retain personal data, we consider: (i) whether we have an ongoing relationship with you; (ii) any applicable legal obligations (for example, laws requiring us to maintain records for specified periods); and (iii) whether we have taken any legal position that requires preservation of the data (for example, legal holds).

The following general retention periods apply, subject to applicable legal requirements:

·         Navigation and browsing data: 6 months, then automatically deleted or anonymized for security reasons (e.g., anti-fraud protection).

·         Purchase and transaction records: for the duration of the contractual relationship and, thereafter, for a period of up to 10 years, or as required by applicable law.

·         Legal and accounting records: for the period required by applicable federal and state law.

·         Legal claims data: for the duration of any legal dispute and until expiration of applicable appeal periods.

·         Direct marketing data (email and SMS): 36 months from the date of your last enabling interaction, or until you withdraw consent or opt out, whichever is earlier. “Enabling interaction" means the receipt and opening of an email or SMS stating that the privacy consent will be renewed for a further 36 months, without prejudice to the right to opt out.

·         Product review data: 36 months from the date of collection and publication of your review.

·         Cookie data: as specified in our Cookie Statement.

Upon expiration of applicable retention periods, personal data will be deleted, destroyed, or anonymized in accordance with our data retention and backup procedures. Rather than delete personal data, we may de-identify it by removing identifying details; where we have committed to maintaining personal data in de-identified form, we will not re-identify it except as permitted by applicable law.

14. Contact Information

For questions about this Statement, to exercise your privacy rights, or to submit a privacy-related request, please contact us:

KIKO USA Inc.

Address: 107 Greenwich Street, Suite 1501, New York 10006

Email: privacykikous@kikocosmetics.com

Webform: https://us.kikocosmetics.com/pages/contact

15. Updates to This Statement

We reserve the right to amend or update this Statement at any time to reflect changes in our practices, applicable law, or other factors. We will post the updated Statement on our Website and update the "Last Updated" date at the top of this Statement. Your continued use of the Website following any update constitutes your acknowledgment of the updated Statement. We encourage you to review this Statement periodically.