Vileda Privacy Policy

FHP Export GmbH is registered with the Local Court of Mannheim under HRB 430574 and whose registered office is at Im Technologiepark 19, 69469 Weinheim, Germany. 

We are committed to protecting and respecting your privacy. This Policy sets out the basis on which any personal data (as defined below) we collect from you, or that you provide to us will be processed by us and why we require it. Please read this Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.vileda.com/en_mena (our website) you are accepting and consenting to the practices described in this Policy. If you have any questions about this Policy or wish to send us a request to exercise any of your legal rights, please contact us vileda-info-mena@fhp-ww.com.

It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide you on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements any other such notices and is not intended to override them.

We are the data controller for the purposes of the relevant data protection legislation. 

WHAT INFORMATION IS COLLECTED? 

“Personal data” means any information which identifies (or from which we can identify) a natural person. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows.

 For information about how this personal data is used please visit the “HOW IS COLLECTED INFORMATION USED?” section of this Policy. 

• Information you give us

  You may give us information about you by filling in forms on our website, corresponding with us by phone, e-mail or otherwise, searching for a product, or when you report a problem with our website. The information you give us may include your first name, maiden name, last name (“Identity Data”), your address, e-mail address, phone number (“Contact Data”)    

• Information we collect about you

  With regard to each of your visits to our website we may automatically collect the following information through the use of log files, cookies or other similar technologies. (which is explained in our Cookie Policy: http://www.vileda.com/en_mena/legal/cookies).

• “Technical Data”, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and 

• “Usage Data” which comprises information about your visit and how you use our website, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. This data is used to improve the customers shopping experience on our website. 

• Information we receive from other sources

  We may receive information about you from other sources, for example if you use any of the other websites we operate or any other service we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, advertising networks, analytics providers and search information providers) and may receive information about you from them. We take steps to ensure that any such third parties are legally permitted or required to disclose such information to us. Examples of information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioural data (such as information about your use of social media websites, page view information and search results and links) from analytics providers and search engine providers (for example, Google). 

• Aggregated Data

  We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data may be derived from your information but does not constitute “personal data” in law as it does not directly or indirectly reveal your identity. For example, we may aggregate (i.e. combine with information relating to others) your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be handled in accordance with this Policy. 

• Special Categories of Personal Data

  We do not collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We also do not collect any information about criminal convictions and offences. We do not knowingly collect and personal data about children.

     

ARE COOKIES USED? 

Our website uses cookies to distinguish you from other users of our website and to enhance customer experience. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them please visit our Cookie page. 

HOW IS COLLECTED INFORMATION USED?

We will only use your personal data when the law allows us to. We have set out below a description of all the ways we intend to use your personal data and which of the legal bases we intend to rely on in order to do so. 

“Legitimate Interests” means the interest of our business in conducting, protecting and managing our business to enable us to give you the best service or products and a secure experience when you use our website. We ensure that we will consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

The information you give to us

• We will use your Identity Data and Contact Data to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us.

• We may use your Contact Data to send you our newsletter and provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about (unless you have opted-out of receiving such communications). This is necessary for our legitimate interests in order to keep you updated about the goods you have purchased, to develop our products and grow our business.

• We will use your Contact Data to notify you about changes or important updates to our service.

• We may use your Identity Data, including your first name and location in order to publish any product review or Tip that you submit to us for marketing purposes (provided that you have opted-in for us to use this information at the time you send us your review).

• If we have obtained your express opt-in consent, we may send you, or permit selected third parties to send you, other forms of marketing relating to other products and services. We will make sure that it is clear when you are able to give us permission to do this, for example, through tick boxes which you will need to tick if you wish to receive such communications. You have the right to withdraw your consent to receiving direct marketing at any time by contacting us.

The information we collect about you 

Your Technical Data and Usage Data will be used: 

• to administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve our website so that content is presented in the most effective manner for you and for your computer;

• to allow you to participate in interactive features of our service, when you choose to do so;

• as part of our efforts to keep our website safe and secure, which is necessary for the running of our business, provision of administration and IT services, network services and the prevention of fraud;

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

• to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.

Information we receive from other sources: 

We may use this information alone or combine this information with information you give to us and information we collect about you for our legitimate business interests in order to enhance our ability to provide relevant marketing and content to you and to help develop and provide you with more relevant products and services.

We will only use your personal data for the purposes of which we collected it, unless we reasonably consider that we need to use it for another lawful reason and that reason is compatible with the original purpose. If you require an explanation as to how the processing of the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent when this is required or permitted by law.

INTERNATIONAL TRANSFERS 

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). Your personal data may also be processed by staff located outside the EEA that work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data you agree to this transfer, storing or processing.

Whenever we transfer your personal data outside of the EEA, we will take all steps reasonably necessary to ensure that your data is treated in accordance with this Policy and that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain Service Providers, we may use specific contracts approved by the European Commission which give personal data the same protection that it receives in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.  .

• Where we use providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield Network, which requires the provision of a level of protection acceptable to the European Commission of personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

INFORMATION SHARING 

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors if it is necessary for the performance of any contract we enter into with them or you in order to provide you with our products.  This includes our software or IT support providers for the purpose of system administration, data security, data storage, back up, disaster recovery and IT support. 

• Advertisers and advertising networks that require the personal data to select and display relevant adverts to you on our website. We and our third party advertisers may use cookies and other tracking technologies such as pixels and web beacons, to gather information about your activities on our website and other sites in order to provide you with targeted advertising based on your browsing activities and interests. 

• Analytics and search engine providers such as Google Analytics that assist us in the improvement and optimisation of our website. For more information, please visit the GOOGLE ANALYTICS section of this Policy

We may also disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Policy.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our company or group companies, our customers, or others.

THIRD-PARTY LINKS 

Our website may provide links to third-party websites (such as social media accounts including Facebook and Twitter), plugins and applications. Our website may also, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. If you follow a link to any of these websites, they will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to any third party websites.

THE USE OF GOOGLE ANALYTICS AND GOOGLE TAG MANAGER  

(1) This website uses Google Analytics, a web analysis service offered by Google Inc. (“Google”). Google Analytics uses “cookies,” text files that are placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and be shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with further services associated with website and Internet use.

(2) The IP address transmitted by your browser in the context of Google Analytics will not be merged with other Google data.

(3) You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do so, you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

(4) This website uses Google Analytics with the extension “_anonymizeIp().”IP addresses are thus further processed in abbreviated form, so that a personal relationship can be ruled out. As far as the data collected about you is personal, it will be excluded right away and the personal data will be deleted immediately.

(5) We use Google Analytics to analyze and regularly improve the use of our website. We can improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google complies with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 Par. 1 S. 1 lit. f GDPR.

(6) Third party information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

User terms: http://www.google.com/analytics/terms/gb.html

and the data protection declaration: https://policies.google.com/privacy?hl=en&gl=zz.

(7) This website also uses Google Analytics for device-independent analysis of visitor flows, which is carried out via a user ID. In your customer account under “My data,” “Personal data,” you can deactivate the cross-device analysis of your usage.

https://myaccount.google.com

(8) Data at the user and event level linked to cookies, user IDs and advertising IDs (e.g. DoubleClick cookies, Android advertising ID, IDFA [Apple Advertiser ID]) will be retained by us for 14 months before it is automatically deleted.

"(9) Using Google Tag Manager: Google Tag Manager is a solution that allows marketers to manage website tags through a single interface. The Tool Tag Manager itself (which implements the tags) is a cookieless domain and does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it remains for all tracking tags implemented with Google Tag Manager. https://www.google.com/analytics/tag-manager/use-policy/

Click here to opt out of Google Tag Manager collection. 

YouTube Video Plugins 

Our website uses video plugins from the video-sharing website youtube-nocookie.com. Youtube belongs to Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“).We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.

You find further information concerning the treatment of user data in the Privacy Policy of YouTube under: https://policies.google.com/privacy?hl=en

HOW LONG WILL WE KEEP HOLD OF YOUR PERSONAL DATA? 

We will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, or for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Further details of retention periods for different aspects of your personal data are available upon request by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

In some circumstances you can ask us to delete your data: see the “Right to be Forgotten” section below for further information.

HOW DO YOU PROTECT AND STORE THE INFORMATION YOU HOLD ABOUT ME ON YOUR SYSTEMS? 

All information you provide to us is stored on our secured servers. We use our best endeavours to ensure that your data is treated securely and in accordance with this Policy and that we will comply with the relevant data protection legislation.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Our confidentiality and database access controls are reviewed periodically and are updated as required in order to ensure that we are handling personal data securely.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please note that the transmission of information via the internet is not completely secure. Although we shall do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we shall use effective safeguarding procedures and security features to try to prevent any unauthorised access to your personal data.

YOUR RIGHTS

Under certain circumstances, you have the following rights:

1. to request that we provide you with a copy of the personal data that we hold about you ("Access Request");

2. to request that we rectify any personal data that we hold about you (“Right to Rectification”);

3. to request that we erase any personal data that we hold about you (“Right to be Forgotten”);

4. to restrict the level of processing we carry out with your personal data (“Restriction of Processing”);

5. to obtain from us all personal data that we hold about you in a structured, machine readable form, and have this information transmitted to another organisation (“Data Portability”);

6. to object to our processing your personal data in certain ways (“Right to Object”); and

7. to withdraw your consent at any time to our processing of your personal data.

Please see the relevant sections below for further details on your rights as a data subject. You can exercise any of the above rights by emailing us at vileda-info-mena@fhp-ww.com. You also have the right to lodge a complaint with the data protection authority if you are unhappy in any way with how we have treated your personal information. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.

We shall comply with any request made under this section as soon as possible, and normally within one month from the date of your request. However, if necessary, for example if your request is particularly complex or we receive a number of similar requests, we may extend this period by an additional two months, but we shall notify you if we need to do this.

You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, please note that where we receive requests under this section which are manifestly unfounded or excessive, for example because they are repetitive in nature, we may:

1. charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or

2. refuse to act on the request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

ACCESS REQUEST 

You have the right to request a copy of the information that we hold about you at any time. This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it. Please note that in most circumstances, we shall not make a charge for this. However, we may charge a reasonable fee based on administrative costs for any further copies requested.

RIGHT TO RECTIFICATION 

You are able to amend and update your contact details and other preferences at any time by contacting us vileda-info-mena@fhp-ww.com. However, you also have the right at any time to ask us to rectify any personal data that we hold for you which is incorrect or incomplete. This enables you to have corrected any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data that you provide to us. If we have disclosed any incorrect or incomplete data to any third parties, we shall inform them of any necessary amendments or corrections made to your personal data under this section.

RIGHT TO BE FORGOTTEN 

You have the right to ask us to erase the personal data that we hold about you in circumstances where:

1. it is no longer necessary for us to handle your personal data for the purpose for which it was originally collected;

2. you have withdrawn your permission for us to hold your personal data (where this was the basis on which it was collected or used);

3. you object to the processing of the data and there is no lawful overriding reason for us to continue processing your personal data;

4. the personal data was unlawfully processed; or

5. we have to erase your personal data in order to comply with a legal obligation.

Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

RESTRICTION OF PROCESSING 

You can ask us to restrict how we use your data in the following circumstances:

1. where you believe that the information we hold about you is inaccurate, you can ask that we refrain from using your data until we can verify the accuracy of it;

2. where we have unlawfully processed your data, you can ask that we restrict our usage of it rather than erase it completely;

3. where we no longer need to hold your information, but you wish us to retain your information for the purpose of establishing, exercising or defending a legal claim; or

4. where you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

DATA PORTABILITY 

You have the right to obtain from us all personal data which you have provided to us in a structured, commonly used and machine readable form, provided that such data was processed based on your consent, or for the purpose of a contract between us and the processing was carried out by automated means.  Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

This will allow you to move, copy or transfer personal data easily from one IT environment to another. Alternatively, we can transmit such data directly to another organisation.

Please note that we shall not be able to comply with a data portability request if this will affect the rights and freedoms of others.

RIGHT TO OBJECT 

You have the right to object, on grounds relating to your particular situation, to our processing of your personal data where we are doing this for the performance of a task carried out in the public interest (which we shall have told you about, if applicable), or where we are carrying out processing for the purposes of legitimate interests pursued by us.

You also have the right at any time to ask us not to process your personal data for direct marketing or profiling purposes (to the extent that such profiling is related to such direct marketing). We shall have informed you before the time we obtained your personal data whether we intend to process your personal data for this purpose, or if we intend to disclose your information to any third party for such purposes.

RIGHT TO WITHDRAW CONSENT 

Where you have given us your consent to our processing of any of your personal data, you have the right to withdraw your consent at any time, for example if you no longer wish us to share your information with third parties for marketing purposes (where you have previously consented to this). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

In addition to any other way we make available to you to withdraw your consent, you may also withdraw your consent at any time by contacting us at vileda-info-mena@fhp-ww.com.  

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this privacy policy at any time. Any changes we may make to our privacy policy in the future will be posted on this page. When edited in any way the date at the bottom of this page will be updated. It is therefore advised to frequently check this page for any changes. 

For information request, please send an email to vileda-info-mena@fhp-ww.com or write to:

Freudenberg Home and Cleaning Solutions GmbH

Data Protection Officer

Im Technologiepark 19

69469 Weinheim

Germany 

Date: 04/09/2018