Freudenberg Household Products Inc. / Vileda Professional is registered in Canada with registration number 1855149.
We take the protection of your personal data seriously. 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 http://vileda-professional.ca (“our website”) you are accepting and consenting to the practices described in this Policy.
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.
Who is responsible for data processing and who can I contact?
We are the data controller for the purposes of the relevant data protection legislation. If you have any questions about this Policy or wish to send us a request to exercise any of your legal rights, please contact our Customer Service Department at CIC.FHPTORONTO@fhp-ww.com
If you have any concerns regarding the way in which your personal data is handled by us or require any further information in this regard, please contact our Data Protection Officer at:
Im Technologiepark 9
You also have the right to lodge a complaint with the Information Commissioner’s Office 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 Information Commissioner’s Office, so please contact us in the first instance.
Which data are processed and from which sources does this data come from?
“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.
- Information you give us
The information you give us may include your first name, last name and salutation (“Identity Data”), your address, delivery address, e-mail address and phone number (“Contact Data”), your order, billing information, bank account details and credit rating information (“Financial Data”), and your interests, preferences, feedback, survey responses and trade fair minutes (“Profile Data”).
- Information we collect about you
- “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 customer experience on our website.
- Information we receive from other sources
- Aggregated Data
- Special Categories of Personal Data
Cookies are small text files which frequently contain a unique identifier and which are saved to your disk from a webserver. Cookies contain information which can later be read by the webserver which stored the cookie. They often consist of a series of characters and numbers and sometimes further information which uniquely identifies your computer.
Some cookies are stored only for the duration of your visit to our website, so-called “Session Cookies”. Others, more permanent cookies can remain on your computer after your visit to our website and our website will access them every time you re-visit our website (so-called “ID Cookies”). Some cookies which are stored during your visit to our website can be read and processed by other companies.
You find additional information regarding the cookies used on our websites under: Cookie List (PDF)
Minimum Required Information
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide the minimum required data when requested, we may not be able to perform the contract we have or are trying to enter into with you or provide you with the information you have requested. If this is the case, we may have to cancel our agreement with you and will notify you accordingly.
For what purposes and on what legal basis is the data processed?
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).
We process personal data only in the context of our business activities, where such processing takes place on the basis of our legitimate interests, due to a contractual relationship between you and us or a pre-contractual relationship of trust, based on your consent, or if you contact us for any reason (for example, at trade fairs, by e-mail, by postal mail, by telephone or through this website).
In particular, personal data shall be processed in the following circumstances:
- We will use your Identity Data, Contact Data, Profile Data and Financial 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. This includes order processing, delivery and invoicing.
- We may also use your Identity Data, Contact Data and Profile Data for the purpose of quality control or dealing with any complaints received regarding our goods or services.
- We may use your Contact Data to notify you about changes or important updates to our products or services, and to 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.
- 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.
- When you visit our premises, we may also use your Contact Data to register you as a visitor in the interests of health and safety, and also to enable you to access our guest Wi-Fi whilst on our premises.
- Your Technical Data and Usage Data will be used to administer and improve our website and as part of our efforts to keep our website safe and secure.
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.
When will we share your personal data?
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Ontario Corporation Number 1855149. This includes your name, address, email address and order details if you have placed an order with us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We shall not share your personal data with any third parties for marketing purposes without your express consent. We shall however, share your personal data with third parties, for the following reasons:
- Service Providers
- Security providers;
- IT support and hosting service providers;
- Credit institutions and payment providers;
- Back office service providers for the processing of advertising mailings;
- Suppliers for handling products and sample orders;
- Laboratories for testing products;
- Logistics companies to send your ordered goods;
- Distributors, if they need your personal data to process your order;
- Agencies for surveys and marketing activities.
- To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition
- To protect the rights, property, or safety of our business and other customers
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website that you visit.
For how long will my data be stored?
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.
How safe is my data?
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.
YouTube Video Plugins
Our website uses video plugins from the video-sharing website youtube.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.
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.
Please note that on this website, Google Analytics code is supplemented by “gat._anonymizeIp();” to ensure an anonymized collection of IP addresses (so called IP-masking).
Under certain circumstances, you have the following rights:
- to request that we provide you with a copy of the personal data that we hold about you (“Access Request”);
- to request that we rectify any personal data that we hold about you (“Right to Rectification”);
- to request that we erase any personal data that we hold about you (“Right to be Forgotten”);
- to restrict the level of processing we carry out with your personal data (“Restriction of Processing”);
- 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”);
- to object to our processing your personal data in certain ways (“Right to Object”); and
- 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 [CIC.FHPTORONTO@fhp-ww.com].
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:
- charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or
- 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.
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.
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:
- it is no longer necessary for us to handle your personal data for the purpose for which it was originally collected;
- you have withdrawn your permission for us to hold your personal data (where this was the basis on which it was collected or used);
- you object to the processing of the data and there is no lawful overriding reason for us to continue processing your personal data;
- the personal data was unlawfully processed; or
- 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:
- 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;
- where we have unlawfully processed your data, you can ask that we restrict our usage of it rather than erase it completely;
- 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
- where you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
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 [CIC.FHPTORONTO@fhp-ww.com].