Privacy Policy

TOTO USA, INC is a wholly-owned subsidiary of TOTO AMERICAS HOLDINGS, INC., a United States subsidiary of TOTO, LTD, operating solely within the Americas.  TOTO USA is committed to your privacy. This Privacy policy applies to our practices in connection with information collected through our websites, services and applications (a “Site” or collectively the “Sites”). By using the Sites, or by providing information to us, you agree that we may use and disclose your information according to the terms of this Policy. 

The use of your information is subject to the Privacy Policy and Terms and Conditions in effect at the time of use. Please read our Privacy Policy from time to time, since we may modify it at any time at our sole discretion. If we make material substantive changes, we will post the revised Privacy Policy on our Site with a new Effective Date. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

Data Processing and Cross-Border Data Transfers

Our Site is intended for use by visitors from the Americas.  We offer translations of our Site into French or Spanish for our visitors from Canada and Central and South America.  The Site is maintained on servers located in the United States, and personal information submitted is stored on our servers in the United States. 

The TOTO Store is available for purchases shipped only into the continental United States and Canada.  Purchases from outside those territories are not permitted. If you are visiting our Site from outside the United States or Canada, please be advised that your information is transferred to our U.S. servers.  Please navigate to the Global tab on the Site to locate the TOTO website serving your location. 

Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk.  By allowing us to collect information about you, all users, including without limitation users in Canada and the European Union, fully understand and unambiguously consent to the collection, such transfer and processing of your data as described in this Privacy Policy. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.

Keeping Your Information Secure

We have implemented and maintain reasonable physical, administrative and technical methods to protect your information. You also play a role in protecting your information. You can help to maintain the security of your online transactions by not sharing your account logon or password with anyone and by changing your password regularly.

Information We Collect and How We Use It

Information You Provide. When you register with TOTO USA, for instance to make a purchase, we collect profile information from you through our registration form. This may include your name, address, e-mail address, shipping address, and telephone number. Providing personal information is solely your choice. However, certain services may not be fully available to you if requested information is not provided. We may also ask you to select a user name and password or identification number to gain access to certain portions of our Site. We may also ask you to provide optional demographic information such as, but not limited to, your zip code, your age range, your business, or your product preferences. When you register for any TOTO USA services, your user name and password are recorded for the purpose of maintaining your own accounts within the Site. Our servers also record e-mail addresses that you submit for registration. If you access our Site through a Social Media account we may also receive information about you, your digital identity, or your contacts from your social media account depending on how you have set your preferences on such account.

Communications with Us.  If you choose to communicate with us, whether by email, telephone, postal mail or by using our online chat feature, we will collect and store the information you provide.  

Our Site may allow residents of the United States and Canada to purchase certain products through our TOTO Store, an independent website which we own and operate. When you place an order we will require that you provide your contact information including address, email address and telephone number, your payment card information and associated billing address and telephone number, and your shipping address. Information about your payment is protected during transmission to us using industry standard technology.

If you would like to e-mail a page or pages from our Site to a friend, we will collect the recipient’s e-mail address for purposes of that transmission. However, we may not maintain a permanent record of that address unless the recipient independently registers with TOTO USA.

We may use the information we collect from you for our legitimate operational and development interests, for example:

• to respond to your requests or inquiries,
• to process transactions you have requested,
• to manage or facilitate the operation and security of the Site,
• to enhance your experience with TOTO USA,
• to communicate with you about transactions or registration, and about products, services, events and other opportunities related to TOTO USA,
• to identify you or authenticate your identity,
• to communicate with you regarding your account with us,
• to monitor and improve the use and satisfaction of Site users,
• to display advertisements relevant to your interests,
• to conduct research and analysis and
• to expand our services and outreach within the United States.

Automatically Collected Information. When a visitor requests pages on the TOTO USA site, our servers automatically recognize the browser’s domain name and IP address. We may also collect statistical information about how visitors are generally searching or using the Site and reserve the right to compile and publish profile information about our visitors without the visitor’s name and addresses for reasonable business purposes.

We do not use technology that recognizes a “do-not-track” signal from your web browser.

Cookies. We may use “cookies” (small pieces of information stored by your browser on your computer’s hard drive) to track sessions and to personalize your experience on our Site so that we may improve our site and better tailor it to meet our users’ needs. You can adjust your browser setting to limit or refuse cookies. If you refuse cookies, this will limit system performance and may even cause certain features of the Site to malfunction or not to work at all. Further general information about cookies and how they work is available at www.allaboutcookies.org. The cookies we use on our Site include:

Session Cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We use session cookies to grant our users access to content and to enable actions they must be logged in to do.

Persistent Cookies: These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve the site for our customers. For example, we may use a persistent cookie to associate you with your user account or to remember that your choices on the Site, but this only works when cookies on our site are enabled.

Third Party Cookies: We permit limited third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. For example, we utilize an analytics program to analyze usage patterns of the Site. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

Your Choices.

We may use your email address to contact you to respond to your inquiries, to send you newsletters or announcements, to invite you to participate in surveys, or to provide information about products or services to you. You can elect not to receive promotional emails from us by unsubscribing using the mechanism provided in an email you receive from us.

How TOTO USA Shares Your Information.

In general, TOTO USA will not share your information with anyone who is not an employee or affiliate of TOTO USA, or who has not signed an appropriate non-disclosure agreement. TOTO USA may disclose personally identifiable information about you to any unaffiliated third party : (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) to allow them to market to you, or (7) as otherwise described in this Privacy Policy.

We may disclose your non-private, aggregated, or otherwise non-Personal Information, such as usage statistics of our Products, to our affiliates and third parties.

Keeping Information Accurate

If you ever find that your account information is not complete, not accurate or not current, please e-mail, call or write to us as noted below. We will correct any erroneous information as quickly as possible.

TOTO USA and Children

TOTO USA’s business and website are not designated to be attractive to children. We do not knowingly collect data from children, and we do not knowingly market to children. Our terms and conditions of use require that any registration may only be made by those over the age of 18. If we have reason to believe that information is being provided by a child under the age of 18 TOTO USA will not collect the information without parental consent or parental notification, which will include the opportunity for the parent to prevent the use of the information or to prevent the child’s participation in the activity. If a child has provided us with personal information, a parent or guardian of that child should contact TOTO USA customer service and request that information be removed. Without parental consent, online information will only be used to respond to an unsolicited request and for no other purposes. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.

Notices for California Residents

Your California Privacy Rights

For California Residents Only. We may disclose your personal information to our affiliates or other third parties including who may use that information to market to you directly. Pursuant to California Shine the Light Act California residents with an established business relationship with us are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please email us at privacy@toto.com or call us at our toll-free telephone number (888) 295-8134 to request a copy of our disclosure pursuant to California law.

California Privacy Act ("CPRA") Notice

CPRA Rights

Verified California residents have the following rights:

• Information Access Rights. California residents have the right to request up to twice in a 12 month period, and receive:
• disclosure of our personal Information Collection Practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
• a copy of the personal information we have collected about them during the prior 12 months, or at your option since January 1, 2022 (Data Portability).
• disclosure of our Information Disclosure Practices during the prior 12 months, including a list of the categories of personal information sold or shared with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.
• Information Correction Right. California residents have the right to request that we correct personal information we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account. You can make information correction requests at any time.
• Information Deletion Right. California residents have the right to request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions. You may make deletion requests at any time. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations.
• Opt Out Rights.
• Do Not Sell My Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. We do not sell personal information as defined in the CPRA.
• Do Not Share My Personal Information. You have the right to opt out of having your personal information shared with third parties for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you. We do not share personal information as defined in the CPRA.
• Limit Processing of Sensitive Personal Information. You have the right to tell us not to process or disclose Sensitive Personal Information for any purpose other than the purposes disclosed at or before the time we originally collected it. We only process or disclose Sensitive Personal Information for the purposes disclosed at or before the time we originally collected it.

For purposes of the CPRA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Making CPRA Requests and Our Responses

• Access, Correction and Deletion. To exercise the access, correction and deletion rights California residents may contact us by calling us at our toll-free number (888) 295-8134, contact us at privacy@toto.com by email or by visiting our page here. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

Any disclosure we provide will only cover the 12-month period preceding receipt of your request, but you may request that we expand the 12-month period to cover information collected since January 1, 2022 and we will honor that expanded request unless doing so would involve a disproportionate effort.  For Data Portability requests we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

• Opt Out Rights. We do not sell personal information for monetary or other consideration and we do not share personal information with third parties for behavioral marketing purposes. Further, we already limit processing or disclosure of Sensitive Personal Information to the purposes disclosed at or before the time we originally collected the information. If, in the future, we engage in any of these activities, we will update this privacy policy and our compliance with the CPRA.

We will not discriminate against you as a result of your exercise of any of these rights.

Using an Authorized Agent.  You may submit a request through someone holding a formal Power of Attorney.  Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us.  We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Information Collected, Sources, and Business Purposes for Collection

During the past 12 months, we have collected the following categories of information about California residents from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties.  The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals.  For instance, we may collect different information from applicants for employment or from vendors or from customers.

CATEGORY OF INFORMATION COLLECTED	SOURCE	BUSINESS PURPOSES* FOR USE	CATEGORIES OF THIRD PARTIES RECEIVING INFORMATION
Identifiers (name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)	Individuals submitting information to us; information we automatically collect from site visitors; information we may receive from third-parties (affiliated companies; marketing and data partners).	Auditing relating to transactions; security detection, protection and enforcement; ad customization; performing services for you; quality control.	Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners); affiliated companies; government regulators; law enforcement when lawfully requested; strategically aligned businesses.
Protected Information (name with financial account, medical, health, and health insurance information, user name and password)	Individuals submitting information; employment applications; employees.	Security detection, protection and enforcement; performing services for you.	Service providers (such as payment processors, employee benefits partners); affiliated companies; law enforcement when lawfully requested.
Protected classification information (race, gender, ethnicity, religion)	Individuals submitting information.	Performing services for you; legal compliance	Service providers (such as employee benefits partners); government regulators; law enforcement when lawfully requested.
Commercial information (transaction history, products/services purchased, obtained or considered, product preference)	Individuals submitting information; information we automatically collect from site visitors; information we may receive from third-party marketing or data partners.	Auditing relating to transactions; ad customization; performing services to you; internal research and development; quality control.	Service providers (such as payment processors, mail houses, marketing partners, shipping partners, professionals), affiliated companies, government regulators, law enforcement when lawfully requested, strategically aligned businesses,
Electronic network activity (browsing or search history, website interactions, advertisement interactions)	Information automatically collected from site visitors.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.	Service providers (such as marketing partners); law enforcement when lawfully requested; strategically aligned businesses.
Audio, video or similar information (customer service calls, security monitoring)	Individuals submitting information; information we collect for security purposes.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; performing services for you; internal research and development; quality control.	payment processors, mail houses, marketing partners, shipping partners, employee benefits partners, professionals); affiliated companies; government regulators; law enforcement when lawfully requested.
Biometrics	Individuals submitting information; Information we collect for security purposes;	Security detection, protection and enforcement; performing services for you.	Law enforcement when lawfully requested.
Geolocation	Information we automatically collect from site visitors.	Security detection, protection and enforcement; ad customization; performing services for you; internal research and development; quality control.	Service providers (such as marketing partners, shipping partners); affiliated companies; government regulators; law enforcement when lawfully requested; strategically aligned businesses.
Professional, educational or employment related information	Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.	Vendor and employee selection, retention and administration; security detection, protection and enforcement; performing services for you; internal research and development; quality control.	Service providers (such as payment processors, employee benefits partners); affiliated companies; government regulators; law enforcement when lawfully requested.
Sensitive Personal Information (Social Security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation.)	Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight	Identity verification; employment and benefits administration; vendor oversight; security detection, protection and enforcement; compliance with law..	Service providers (such as payroll processors, employee benefits partners, professional advisors); government regulators; law enforcement (if lawfully requested).
Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)	Internal analytics	Ad customization; internal research and development; quality control.	Service providers (such as marketing partners); affiliated companies.

*More specifically, the business purposes include:

1. Performing services for you:
   • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
   • To assist you in completing a transaction or order;
   • To allow tracking of shipments;
   • To prepare and process invoices;
   • To respond to queries or requests and to provide services and support;
   • To provide aftersales customer relationship management;
   • To create and manage our customer accounts;
   • To notify you about changes to our services and products;
   • To administer any promotion, contest, survey, or competition;
   • To provide you information regarding our products and services,
   • To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.
   • To manage your employment or vendor relationship with us, including for:
     • Onboarding, including background screening processes;
     • timekeeping, payroll and expense report administration;
     • employee benefits administration;
     • the creation, maintenance, and security of you online employee or vendor accounts;
     • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
     • workers' compensation claims management, ADA, FMLA, EEOC, regulatory complaint management, lawsuits;
     • other human resources and vendor administration purposes.
   • To manage and monitor employee or vendor access to company facilities, equipment, and systems.
   • We use and process Sensitive Personal Information to comply with laws including anti-discrimination laws and disablity accommodation laws.
2. Advertising customization:
   • For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.
3. Auditing relating to transactions, internal research and development:
   • To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
   • To create products or services that may meet your needs;
   • To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.
4. Security detection, protection and enforcement; functionality debugging, error repair:
   • As part of our efforts to keep our Sites safe and secure;
   • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
   • To ensure the physical security of our premises through the monitoring of surveillance images;
   • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.
5. Quality control:
   • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
   • To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments

Processing Sensitive Personal Information. We collect and process or disclose Sensitive Personal Information for the purposes disclosed above or at the time we collect this information. We do not process this information for purposes other than the purpose for which it was originally collected unless required by law. We use and process Sensitive Personal Information collected from California employees, job applicants or vendors (including racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status) to comply with laws including anti-discrimination laws and disability accommodation laws. We use Sensitive Personal Information from other consumers (including racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status) to provide disability accommodations.

Disclosing Personal Information

We may disclose your personal information to a third party or governmental agency for a business purpose, When we disclose to a business we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. Please see above for the categories of recipients of each category of information.

We do not sell or share personal information as defined in the CPRA and do not disclose Sensitive Personal Information except as described in this Notice.

Notice to Nevada Residents

We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at privacy@toto.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

Notice to Colorado, Connecticut, Virginia and Utah Residents

We are currently not subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future we will update this Privacy Policy accordingly.

Access to Your Information

In some jurisdictions outside of the United States you may have the right to receive disclosure from us regarding the information we hold about you. Please send your written request either by post or email to the addresses as set out in Contact Us section along with your full contact details. If you wish us to cancel, and/or stop the processing of your personal information we will, subject to our discretion, cancel and/or stop the processing of the personal information. We will not delete information that we are required to retain for our business operations or legal compliance. We may require that you provide adequate identification information or documentation before providing you the information about you that we hold; this is for your protection. We will respond to requests from outside the United States within 20 days of receipt and authentication.

How to Contact Us

This site is owned and operated by TOTO USA, Inc. If you have any questions, complaints, or suggestions with respect to this policy, or the any requests regarding your personal information, or if you wish to ask us to delete, correct, or show you your information as provided above, please contact us at privacy@toto.com by e-mail, by telephone at 770-282-8686, or by mail at:

TOTO USA
Attn: Website Manager
1155 Southern Road
Morrow, GA 30260