What is personal data?
Personal data is all information that directly or indirectly (i.e. together with other information) may identify an individual. This means that a wide range of data, such as names, contact details, IP addresses, and behaviour and choices made online are personal data.
Data processing is any operation or set of operations performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, storage, adaptation or alteration, blocking, erasure or destruction of personal data.
How do we process your personal data?
Visitors to our websites and digital channels
When you visit our websites and digital channels we may process:
- Information you have volunteered, such as name, date of birth and contact details;
- details of your visits to our websites and digital channels, this may include search terms you use, likes, shares;
- campaign traffic data;
- sales via this website;
- personal information that does not identify you (”Grouped Data”). Grouped Data may include gender, region, household and age;
- technical data, which may include URL information, cookie data, your IP address, the types of devices you are using to access Cloetta websites; and
We process your data for the following purposes:
- To monitor and improve our products and services, e.g. in order to optimise the website and our digital channels, make it more user friendly and for follow up [and statistical purposes, if applicable];
- to measure the performance of an advertising/digital campaign;
- to target and reach audience online;
- to communicate with you, e.g. through our digital channels, monitor social posts, brand sentiments and newsletters;
- to analyse information for individual profiling in order to offer personalized ads, offers and other customized information; and
Customers buying our products online
When you are a customer buying our products online we may process:
- Information you have volunteered, such as name, gender, home and/or delivery address, telephone number, e-mail address, data of birth, demographical information, interests, preferences, payment information; historical order information; and product you bought.
We process your data for the following purposes: To handle our customer relation e.g. identifying you as a customer; and to fulfil the contractual obligations e.g. provide services.
Subscribers to newsletters or to marketing contests
Consistent with the permission you have given us by opt-in and by consenting to our terms and conditions we may process:
- Name, gender, telephone, address, email address and date of birth
We process your data for the following purposes: Direct marketing purposes including providing you with newsletters, offers and promotions on products and services by email, if you have requested such information. You can opt-out from these by clicking a link in each message sent through email (unsubscribe).
When you communicate with us
When you communicate with us we may process:
- Information you have volunteered such as your name, home and/or delivery address, telephone number, e-mail address, data of birth, demographical information, interests, preferences, payment information and case information.
We process your data for the following purposes:
To fulfil a request from you or respond to your inquiries e.g. to handle customer complaints.
Legal ground for our processing
Cloetta processes personal data in accordance with applicable personal data protection legislation. Within the EU/EEA, the general data protection regulation (”GDPR”) will apply from 25 May 2018. (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
We will process your personal data when it is necessary to (i) fulfil a request from you or respond to your inquiries (ii) comply with a legal obligation. Your data may also be processed when it is necessary for the purposes of a legitimate interest for Cloetta, inter alia, to market, improving our services. If a certain data process requires your prior consent, we will collect such consent before carrying out the processing in question.
Personal data that we request from you and indicated as mandatory is required to be provided in order for us to provide the service, e.g. for statutory, contractual, administrative or technical reasons.
How long do we keep your information?
We will only keep your information for as long as we need it: (i) to provide you with a product/service; (ii) to improve our services; and (iii) for legal and audit purposes. We have routines in place to ensure that personal data is deleted thereafter.
How do we share your information?
Cloetta may engage third parties for the provision of services to Cloetta, such as provision of IT-systems, services and other activities. Your data may be shared with and processed by such service providers on behalf of Cloetta as required for the provision of the services to Cloetta. Within the use and provision of such services, your personal data may be transferred to countries outside the EU/EEA (third countries). In relation to such third country transfers, certain security measures will be taken in order to protect your data and ensure that the data keeps an adequate level of protection, e.g. by entering into a data transfer agreement including model clauses issued by the EU Commission and available on the EU Commission’s website.
Personal data may be disclosed to a third party if we are required to do so according to applicable laws and regulations or in order to detect and prevent fraud or other security or technical problems.
Companies which are processing personal data on behalf of Cloetta are obliged to sign an agreement with Cloetta in order to ensure a high level of protection for your personal data.
We strive to provide a high level of protection in all our personal data processing. We have therefore taken organisational and technical security measures in order to protect your personal data from unauthorised access, use, alteration and erasure.
Your rights under applicable data protections legislation
According to applicable data protection legislation, you are entitled to certain rights. If you want to exercise any of these rights, please contact us at the address specified in section “Contact information”.
As specified in applicable data protection legislation, you have the right to:
- Request access to and rectification of the personal data we process in relation to you;
- request erasure of your personal data;
- request that we restrict the processing of your personal data;
- object to the processing of your personal data and, in respect of processing based on your consent, to withdraw your consent at any time; and
- receive personal data about you that you have provided to us.
You are also entitled, at any time, to submit complaints to the relevant supervisory authority if you think that your personal data is being processed in violation of the applicable data protection legislation.
The entity listed as the responsible entity for the digital channel in question is the data controller for personal data processed in relation to that digital channel. Where applicable, other legal entities within the Cloetta group may furthermore be data controllers for personal data processing in accordance with the terms of the respective service or function. If you have any questions regarding the processing of your personal data or want to exercise any of your rights under applicable data protection regulation, you may reach out to us via the following contact details.
Cloetta UK Ltd
Address: Fort Southwick, James Callaghan Drive, Fareham, Hampshire, PO17 6AR
Updates to the policy