Statement on Privacy
INTRODUCTION
Danone knows that you care how your personal data is used and We recognize the importance of protecting your privacy.
This Privacy Statement explains how Danone S.A. and all its subsidiaries (“Danone”, “We”, “Our” or “Us”), acting as Data controller, collect and manage your personal data when you visit Our Corporate website available at www.danone.ie. It contains information on what data We collect, how We use it, why We need it and how it can benefit you. Please see Our Data Controllers and How to Contact Us section for more information on which Danone subsidiaries act as the Data Controller.
Contact us here if you have any queries and comments, or if you want to make a request regarding any of your data subject rights.
This privacy statement was last updated on January 25, 2021.
BASIC PRINCIPLES AND OUR PRIVACY COMMITMENT
At Danone We are committed to protecting your right to privacy. We aim to protect any personal data We hold, to manage your personal data in a responsible way and to be transparent in Our practices. Your trust is important to us. We have therefore committed ourselves to the following basic principles:
· You have no obligation to provide any personal data requested by Us except as required by law or to perform any contract We have with you. However, if you choose not to, We may not be able to provide you with some services or products;
· We only collect and process your data for the purposes set out in this Privacy Statement or for specific purposes that We share with you and/or that you have consented to;
· We will only collect, process and use the minimum required personal data and not more than is required for the purposes as described in this Privacy Statement;
· When We do collect your personal data, We aim to keep it as accurate and up to date as possible;
· If the personal data We collect is no longer needed for any purposes and We are not required by law to retain it, We will do what We can to delete, destroy or permanently de-identify it;
· Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement.
WHAT PERSONAL DATA DO WE COLLECT?
By personal data, We refer to any information about a person from which that person can be identified. This does not include data for which the identity has been deleted (anonymous data).
The personal data We collect varies depending upon the purpose of the collection and the product or service We are providing you.
Danone may collect and use the following categories of personal data from you directly:
a) Personal contact data, such as your name, email address, physical address and telephone numbers;
b) Communications with Us, which may include details of Our conversations via chat, care lines and/or customer service lines;
c) Demographic information, such as your date of birth, gender and lifestyle preferences. Lifestyle preferences may include your preference for some of the products We offer, and your interests related to those products;
d) Browser history, such as pages accessed, date of access, location when accessed, and IP address; and
e) Information about people other than you, such as personal data about your family members, when you provide such information directly to Us.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data directly from you via the following sources, this collection includes when:
· you fill in Our forms or correspond with Us by post, phone, email, chat or otherwise
We may also collect personal data about you indirectly when:
· you share content on social media pages, websites or applications related to Our products or in response to Our promotional material on social media; or
· We read or collect personal data about you by reading information collected by other websites (for instance, We may place an advertisement on a third party website, and when you click on that advertisement, We may receive information about you and other website visitors in order to measure the reach and success of that advertisement).
WHY DO WE COLLECT AND USE YOUR PERSONAL DATA?
We collect your personal data so We can perform any contract We have with you, provide you with the best online experience and to provide you with a high quality of customer service.
In particular We may collect, hold, use and disclose your personal data for the following purposes:
a) To process and answer your inquiries or to contact you in order to answer your questions and/or requests;
Legal basis: Necessary for the performance of a contract; Legal obligations; Necessary for Our legitimate interests (to improve customer service management)
b) To authenticate the identity of individuals contacting Us by telephone, electronic means or otherwise;
Legal basis: Necessary for the performance of a contract; Legal obligations; Necessary for Our legitimate interests (to help Us confirm the identity and prevent fraud)
c) For internal training and quality assurance purposes;
Legal basis: Necessary for Our legitimate interests (to improve customer service management)
d) To manage Our relationship with you which may include notifying you about changes to Our terms or privacy policy or asking you to leave a review or take a survey
Legal basis: Necessary for the performance of a contract; Legal obligations; Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our product/services)
e) To develop and improve Our products, services, communication methods and the functionality of Our websites;
Legal basis: Necessary for Our legitimate interests (to define types of customers for Our products and services, to keep Our website updated and relevant, to develop Our business and to inform Our marketing strategy)
f) To understand and assess the interests, wants, and changing needs of customers, in order to improve Our website, Our current products and services, and/or developing new products and services;
Legal basis: Necessary for Our legitimate interests (to analyse how customers use Our products/Services, to develop them and grow Our business)
We may also need your personal data to comply with legal obligations or in the context of a contractual relationship that We have with you.
When We collect and use your personal data on the legal basis of Our legitimate interests, We believe the risk to your data protection rights in connection with personal data is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.
When We collect and use your personal data for new purposes, We will inform you before or at the time of collection.
Where legally required to do so or where appropriate, We will ask for your consent to process the personal data. You have the right to withdraw your consent at any time by informing Us of your decision. If you wish to withdraw your consent, please contact Us via this link.
YOUR RIGHTS
You are entitled to a number of rights and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by contacting Us via this link.
Some of these rights only apply in certain circumstances and so are not guaranteed or absolute rights. Please contact Our Data Protection Officer if you have any questions about your rights.
The right to access your personal data and correction
You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact via this link.
The right to data portability
Your personal data is portable. This means it can be moved, copied or transmitted electronically. However, this right only applies where:
a) The processing is based on your consent;
b) The processing takes place for the performance of a contract;
c) The processing takes place by automated means.
If you wish to exercise your right to data portability, please contact Us via this link.
The right to deletion of your personal data
You have right to request that We delete your data if:
a) your personal data is no longer necessary in relation to the purposes for which We collected it; or
b) you withdraw the consent that you had previously given Us to process your personal data, and there is no other legal ground to process that personal data; or
c) you object to Us processing your personal data for direct marketing purposes; or
d) you object to Us processing your personal data for Danone’s legitimate interests (such as improving overall user experience on websites);
e) the personal data is not being processed lawfully; or
f) your personal data needs to be deleted to comply with the law.
If you wish to delete the personal data, We hold about you, please contact Us via this link, and We will take all reasonable steps to respond to your request in accordance with Our legal obligations. 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.
If the personal data We collect is no longer needed for any purposes and We are not required by law to retain it, We will do what We can to delete, destroy or permanently de-identify it. This is discussed in further detail below.
The right to restriction of processing
You have the right to restrict the processing of your personal data if
a) you do not believe the personal data We have about you is accurate; or
b) the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer Us to restrict processing instead; or
c) We no longer need your personal data for the purposes We collected it, but you require the data in order to establish, exercise or defend legal claims; or
d) you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.
If you wish to restrict Our processing of your personal data, please contact Us via this link, and We will take all reasonable steps to respond to your request in accordance with Our legal obligation.
The right to object
You have the right to object to the processing of your personal data at any time. Please contact Us via this link.
The right to withdraw consent
Where legally required to do so or where appropriate, We will ask for your consent to process the personal data. When We process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that took place prior to this withdrawal. If you wish to withdraw your consent, please contact Us via this link.
The right to lodge a complaint with a supervisory authority
While We would be grateful if you lodged any complaints with Us, you have the right to lodge a complaint directly with the Data Protection Commission’s Office about how We process personal data.
For more information about your privacy and data protection rights, or if you are not able to resolve a problem directly with Us and wish to make a complaint, please contact the Irish Data Protection Commission at:
Mailing Address: Canal House, Station Road, Portarlington, R32 AP23 Co. Laois
Phone Numbers: +353 57 8684800 or +353 (0)761 104 800
Email Address: info@dataprotection.ie
You can also contact Our Data Protection Officer directly at DPO.UKIE@danone.com
PERSONAL DATA RETENTION PERIOD
We will only retain your personal data for the minimum time necessary to achieve the purposes for which We collected it as set out in this Privacy Statement, included to comply with any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, We take into account the quantity, nature and sensitivity of personal data, the potential risk of harm resulting from the unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and the possibility of attaining those purposes by other means, as well as the applicable legal regulatory, tax, accounting or other requirements.
After the established deadlines, the data is either deleted or retained after being anonymized, especially for statistical purposes. It may be retained in case of pre-litigation and litigation. It should be noted that deletion or anonymization are irreversible operations, and that Danone is no longer able, thereafter, to restore this data.We may also collect personal data about you through the use of cookies and other technologies. This may occur when you visit our sites or third-party sites, view our online promotions, or use our/third-party mobile applications and may include the following information:
HOW WE PROTECT YOUR PERSONAL DATA
We understand that the security of your personal data is important. We make Our best efforts to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure. We have implemented a number of security measures to help protect your personal data. For example, We implement access controls, use firewalls and secure servers, and We encrypt personal data.
SHARING OF YOUR PERSONAL DATA
When We share your personal data with Danone affiliates and other organizations, We make sure We only do so with organizations that safeguard and protect your personal data and comply with applicable privacy laws in the same or similar way that We do.
Trusted third parties may assist Us in providing specific services or functions on Our behalf, such as IT services including platform providers, hosting services, maintenance and support on Our website and /or database as well as on Our software and applications that may contain data about you or to perform on Our behalf the statistical analyses associated with the use of the corporate website; Our data management and CRM platform to adequately manage Our relationship with you and fulfil requests made by you.
Your personal data may be shared with Our other UK or Ireland Danone entities so that We can effectively and efficiently process, handle and respond to any complaints or queries.
Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement. We may, however, share your data when required by law and/or government authorities.
If we decide to reorganise or to sell our business or our company, directly or indirectly through a sale, merger, or acquisition, we may share your personal data with actual or prospective purchasers of the business, or of our company. We will require that any such purchasers treat your personal data consistently with this Privacy Statement.
SHARING DATA INTENTIONALLY
Personal data may be processed outside the European Economic Area (EEA). When processed outside the EEA, Danone will make sure that this cross-border data processing is protected by adequate safeguards.
The safeguards that We use to protect cross-border data processing include:
a) Standard Contractual Clauses approved by European Commission. These standardized contractual clauses provide sufficient safeguards to meet the adequacy and security requirements of the European General Data Protection Regulation; or
b) certifications which demonstrate that third parties outside of the EEA process personal data in a way that is consistent with the European General Data Protection Regulation. These certifications are approved either by the European Commission, a competent supervisory authority or a competent national accreditation body in terms of General Data Protection Regulation; or
c) an adequacy decision of the European Commission pursuant to Article 45 of the European General Data Protection Regulation.
We may share your personal data within Danone subsidiaries as detailed above. This may involve transferring your data outside the EEA to our UK based entities.
COOKIES AND OTHER TECHNOLOGIES
We may also collect personal data about you through the use of cookies and other technologies. This may occur when you visit Our sites or third-party sites, view Our online promotions, or use Our/third-party mobile applications and may include the following information:
a) Information about your device browser and operating system;
b) The IP address of the device you are using;
c) Web pages of ours that you view;
d) Links that you click while interactive with Our services.
Please see Our cookie statement for more information on this.
CHANGES TO THIS PRIVACY STATEMENT
This notice was last updated on 25 January 2021. We reserve the right to change this notice at any time (for example, to comply with changes in laws or regulations, Our practices, procedures and organisational structures, requirements imposed or recommended by supervisory authorities or otherwise). Changes to this notice shall be applicable on the effective date of implementation. Please refer to Our website for the latest version of this notice. We will also communicate any changes to you, where We are legally required to do so.
THIRD-PARTY LINKS
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 policy of every website you visit.
DATA CONTROLLERS AND HOW TO CONTACT US
If you have any questions, comments or complaints regarding this Privacy Statement or the processing of your personal data, please contact Us via this link or write to Us at:
Data Protection Officer, Nutricia Ireland Limited, Block 1, Deansgrange Business Park, Deansgrange, Co Dublin, A94 P9T3, Ireland
You can also contact Our Data Protection Officer directly via email at: DPO.UKIE@danone.com