PRIVACY AND DATA PROTECTION POLICY
We take data protection and confidentiality very seriously and comply with all applicable national and European data protection provisions. We outline below information concerning how we collect, process and use data including in particular, what information and personal data we store, and what we do with it.
The controller of your personal data in accordance with Art. 4 (7) of the EU General Data Protection Regulation (“GDPR”), is
49324 Melle, Germany (“we” or “us”).
2. Collection, Processing and Use of Personal Data
2.1. Personal Data
Personal data is defined as any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
This shall include, for example, your name, email address, telephone number, address, date of birth, as well as any data that you provide to us in connection with an online order, a registration, the creation of a customer account or a query submitted via the contact form (“Personal Data”).
2.2. Legal Bases of Collection, Processing and Use of Your Personal Data
In general, it is possible to use our websites without entering any Personal Data. Insofar as our webpages collect any Personal Data, this shall occur on a voluntary basis wherever possible.
In the event you enter our Website due to one of the below listed reasons, please find further details in the following sections:
2.2.1. For our business relationship
We will collect and process your name, email address and any other information you provide to us to handle the business relationship between us, for example to answer your query, to process the agreement made with you, or for technical administration purposes that need to be fulfilled in light of our business relationship. The legal basis for the processing is the necessity of your Personal Data processing for the performance of the respective contract(s) with you pursuant to Article 6 1. (b) GDPR.
We will retain this Personal Data for the period of time that our business relationship lasts. If there have not been transactions or communications between us for three years, we delete or anonymize your Personal Data, unless we are required by law to store it for a longer period.
2.2.2. Newsletter subscription & analysis of newsletter use
If you subscribe to our email newsletter mailing list, we use your Personal Data - submitted by you with your consent - for sending email newsletters to you regularly in order to keep you updated e.g. on current interesting topics or offers.
You need to submit your email address and you may be asked to provide general information on your pet in order to register and receive the relevant information for your pet. We may also process details in relation to newsletters sent, for example recipients and time of sending. The newsletters may contain current offers, quizzes, general pet care and grooming tips, news and other information about our products as well as general advice and information regarding matters revolving around our products. The legal basis for this processing is your consent pursuant to Article 6 1. (a) GDPR.
We may share your Personal Data with third party agencies (including Creative Race and Speed Communications), who manage our CRM databases for newsletter sign-up’s.
You may revoke your consent by unsubscribing from our email newsletter mailing list at any time, without reason and with immediate effect. You can unsubscribe via the unsubscribe link at the bottom of our email newsletters, by using our contact form, or by sending an email to email@example.com.
We will process and retain your Personal Data for this purpose until you unsubscribe. We will then move your Personal Data to a suppression list to make sure you will not be contacted via our newsletter again; your Personal Data will not be used for any other purpose.
b) Analysis of newsletter use
We continuously seek to improve our services. With this in mind, we may carry out an evaluation of email newsletters we send to you, e.g. whether the submitted email addresses are available, whether the newsletter has been opened, which links in the newsletters have been used and whether there is any response or return ((automatic) reply, error message etc.). The legal basis for this processing is our legitimate interest to understand how individuals interact with our newsletters to enable us to improve our services pursuant to Article 6 1. (f) GDPR.
We will retain your Personal Data for this purpose for two years. We will then delete or anonymize your Personal Data, unless we are required by law to store it for a longer period.
2.2.3. Product Reviews (Bazaarvoice)
We collect Personal Data from you when you submit a product review via our Website. This information includes your chosen nickname, email address, IP address, review text, and your ratings, as well as any additional information you voluntarily provided, such as your location, age range, gender, details of where you purchase the product, details relating to your pet ownership or photo, which make your review more comprehensive or interesting for other users.
The data provided will be processed for the use of the product review and displayed on our Website unless you withdraw your consent. We and our service providers (see details below) may use the email address provided to contact you as part of your product review for administrative issues. The legal basis for this processing is your consent pursuant to Article 6 1. (a) GDPR.
We will share your Personal Data with Bazaarvoice to provide customers with rating options for our products. Please see https://www.bazaarvoice.com/legal/privacy-policy for further information in relation to how Bazaarvoice processes your Personal Data.
2.2.4. User Generated Content
Where you have given us permission to use your picture(s) or video(s) (in accordance with respective terms and conditions), such Personal Data will be processed for use on our Website and throughout our social media channels, as well as those of our affiliated companies, in accordance with the license given by you. The legal basis for this processing is your consent pursuant to Article 6 1. (a) GDPR.
We will retain the Personal Data embodied in the picture(s) or video(s) on our Website until the end of the applicable campaign.
2.2.5. “Find Stockists” listing
We offer our business partners and product retailers to be listed in the “Find Stockists” section of our Website.
To register, we need the name and full address of your business, which may include Personal Data such as your personal name. Additional information such as your phone number and website address may be submitted voluntarily, and may help speed up the enlisting process.
We require this information to check the validity of your request and to enlist you on the “Find Stockists” list, where your store location and well as any other of the information listed above will be shown.
The legal basis for this processing is performance of the respective contract pursuant to Article 6 1. (b) GDPR.
We will keep this Personal Data for as long as you are listed. Your details will be removed from the listing if you withdraw your consent, if we find out the information is not correct anymore and cannot be corrected, or if we have any other legitimate reason to end the listing, for example if our overall business relationship has ended and you have stopped to carry our products. We will then immediately delete your data from this list.
You may withdraw consent by contacting us via firstname.lastname@example.org at any time, without reason and with immediate effect. We will then delist you as described above.
2.2.6. Money Back Guarantee
If you request a refund from us by completing the Money Back Guarantee form on our Website, we will process any Personal Data you provide to us in this form, including name, address, email address, date of birth and details relating to your purchase and the refund process.
The legal basis for this processing is performance of a contract pursuant to Article 6 1. (b) GDPR, as we process your Personal Data in order to process your request for a refund. We will retain your Personal Data for this purpose for as long as necessary to fulfil this purpose and for the purposes of satisfying any legal, accounting, or reporting requirements.
2.2.7. Stop the Fakes/Catch the Crooks
If you report a suspected counterfeit product via our Website, we will process any Personal Data you provide to us in the form, including name, address, email address and details relating to your purchase and report as well as the further process.
The legal basis for this processing is our legitimate interest pursuant to Article 6 1. (f) GDPR, to identify counterfeit products to ensure the well-being of our customers and their pets.
We will retain your Personal Data for this purpose for as long as necessary to fulfil this purpose and for the purposes of satisfying any legal, accounting or reporting requirements.
2.2.8. Job applications/ Job candidates’ Personal Data
If you apply for a job in our company we need to collect your personal data including name, email/ postal address etc. as well as information regarding your professional qualifications. These data will be processed in order to execute the application process, the legal justification is Article 6 1. (b) GDPR. As part of the application process you provide these data voluntarily.
Generally we delete your Personal Data as soon as they are no longer needed for the application process (six months after the application process has been finished, e.g. in case of a non-successful application). This does not apply if legal regulations prohibit the deletion or if the data needs to be stored for purpose of evidence, e.g. in case of claims against our company. In this case the processing of your data is based on legitimate interest pursuant to Article 6 1 (f) GDPR.
In case you consent, we will store your Personal Data for a time period of two years after the end of the year in which the application process was concluded, in order to process any potential further applications you might hand in. The respective legal justification for the processing of your data is Article 6 1. (a) GDPR.
In our application process we do not perform any automated individual decision-making according to Article 22 GDPR.
2.3. Consent of minors
Persons aged under 16 may not submit any Personal Data to us without the prior consent of their parents or legal guardian.
2.4. Where you consent: Right to withdraw consent
Where your consent is the legal basis for the processing of your Personal Data, you can withdraw your consent at any time without reasons. Please note that withdrawing your consent will not affect the lawfulness of the processing before the withdrawal. Please see Section 4 below for further details of your rights in respect to the Personal Data we hold about you.
3. How we share your Personal Data with third parties
In addition to the third party recipients outlined at section 2 above, your Personal Data may be transferred to third parties in the following cases:
- To our affiliated companies within the Spectrum Brands group;
- To third-party service providers, including but not limited to advisors and technology service providers;
- To a prospective seller or buyer in the event of a sale or purchase of any Spectrum Brands group business or asset so that the buyer can continue to provide you with information and services; and
- To courts, arbitration bodies, law enforcement authorities, regulators or attorneys if necessary to comply with the law or for the establishment, exercise or defense of rights or legal claims.
Insofar as we contract other companies to carry out tasks on our behalf within the framework of a data processing agreement and forward your Personal Data for this purpose, said company or companies shall be required to protect your Personal Data and to use the latter only for the specific purpose outlined in the agreements with these processors.
In cases we transfer, depending on your location, Personal Data to countries outside the EU/EEA, we have implemented appropriate safeguards to protect your Personal Data, such as entering into EU Standard Contractual Clauses with the recipient or ensuring the recipient is certified under the Privacy Shield.
You may request further information about the safeguards we implement, such as copies of the respective safeguards, by contacting email@example.com. We will process any request in line with any local laws and our policies and procedures.
4. Your rights concerning your Personal Data
If certain requirements are fulfilled, you may have the following rights under GDPR concerning the Personal Data we hold about you:
- Right of access, Art. 15 GDPR: You may ask us to confirm whether we are processing your Personal Data and, if so, to provide you with a copy of that Personal Data (along with certain other details).
- Right to rectification, Art. 16 GDPR: If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to ask for rectification or completion.
- Right to erasure, Art. 17 GDPR: You may ask us to delete or remove your Personal Data in some circumstances, e.g. if we no longer need it or you withdraw your consent (where applicable).
- Right to restriction of processing, Art. 18 GDPR: You may ask us to restrict the processing of your Personal Data in certain circumstances, e.g. if you object to us processing it.
- Right to data portability, Art. 20 GDPR: You have the right to obtain Personal Data you have provided to us in a structured, commonly used and machine-readable format for reuse under certain circumstances.
- Right to object to the processing, Art. 21 GDPR: You may ask us at any time to stop processing your Personal Data, and we will do so, if we:
- rely on legitimate interests to process your Personal Data except if we can demonstrate effective legal grounds for the processing; or
- process your Personal Data for direct marketing.
- Rights in relation to automated decision-making and profiling, Art. 22 GDPR: You have the right not to be subject to a decision that is based solely on automated processing, including profiling.
- Right to revoke consent: If you have consented to us processing your Personal Data, you have the right to revoke your consent at any time.
According to Art. 77 GDPR, you may also be entitled, in accordance with applicable law, to lodge a complaint with the supervisory authority in your country, if you consider that our processing of your
Personal Data infringes applicable law.
For more information on your rights and accordant requirements, please see the information provided by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
You may contact us to exercise your rights as follows:
Tel. 00 800 241 53 414
We shall respond to your request in accordance with the applicable legal provisions and our policies and procedures. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
5. Third Party sites
The Website may contain links to non-Spectrum Brands websites (for example via the ‘Where to Buy’ page). Links to other websites are provided for information purposes only and do not constitute endorsements of those other websites.
To learn more about our policy on cookies, click here to read our Cookies Policy.
7. Data Security
We have implemented and maintained reasonable administrative, physical, technical and organizational security measures designed to protect your Personal Data from unlawful destruction, manipulation, loss, alteration, unauthorized disclosure, or unauthorized access. These security measures are subject to permanent improvement in line with the respective actual technological developments. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk.
8. Questions & Contact
© Tetra GmbH July 2019