SCHOLL'S WELLNESS COMPANY LIMITED - UK PRIVACY NOTICE
Welcome to Scholl’s Wellness Company Limited’s Privacy Notice ("Privacy Notice").
We are committed to protecting your privacy. This Privacy Notice explains how we collect, use, disclose and protect your Personal Data and respect any rights you benefit from under data protection law.
In this Privacy Notice "we", "us" and "our" refers to Scholl’s Wellness Company Limited.
We are the Controller of your Personal Data and our registered office is at:
2 Arlington Square, Downshire Way, Bracknell, RG12 1WA.
By "Personal Data" (in some countries referred to as "personal data" or "personally identifiable information") we mean any information relating to an identified or identifiable individual. This is broader than just information of a personal or private nature, and also includes information such as your name, date of birth, and e-mail address. Please see Section 3 below for what Personal Data is obtained from you.
By “Sensitive Personal Data” (in some countries referred to as “sensitive personal information” or “special categories of data”) we mean any Personal Data relating to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data processed for the purpose of uniquely identifying that individual, data concerning health, or data concerning an individual’s sex life or sexual orientation. It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws.
- Scope of our Privacy Notice
- How do we obtain your Personal Data
- For which purposes may we use your Personal Data
- Legal basis for processing
- To whom we may disclose your Personal Data
- How we protect your Personal Data
- Your choices regarding direct marketing
- Your rights
- How long we retain your Personal Data
- Transfers to other countries
- How to contact us
- Changes to this Privacy Notice
1. Scope of our Privacy Notice
Our Privacy Notice applies to all Personal Data we collect, use, share or otherwise process through our business activities, both online and offline, which display, link or refer to this Privacy Notice, including:
- our websites;
- our official social media pages;
- our e-mails;
- our apps;
- our online and offline campaigns; and
your conversations or correspondence with our representatives.
Throughout this document, we will refer to our online activities as "Sites" and to our offline activities as "Services".
You should be aware of the fact that our Sites may contain hyperlinks to third party websites, apps, etc. which are not controlled by us and which are not covered by this Privacy Notice. We have no responsibility or liability for the content and activities of these third party websites, apps, etc. As these third parties may collect your Personal Data, we suggest that you consult the privacy policies of these third parties to learn more about their use of your Personal Data.
2. How do we obtain your Personal Data?
Personal Data obtained from you directly
Firstly, we may obtain your Personal Data from you directly, e.g. when you sign up for our newsletters, register on our Sites, buy a product from us, fill out a survey, make a comment or enquiry, post something on our social media pages, subscribe to direct marketing etc.
Personal Data collected this way may include:
- e-mail address
- user name
- telephone number (and recordings when you call our consumer line)
- credit card or other payment information
- date of birth
- product purchase and usage information
- household information
- information, feedback or content you provide regarding your marketing preferences
- user-generated content, posts and other content you submit to our Sites
- in limited circumstances, information about your family or other individuals that you have provided to us. In such cases, we assume that you have the authority to share any Personal Data you provide to us about them
- in limited circumstances based on your explicit consent or for carrying out our legal obligations or if necessary for reasons of substantial public interest, Sensitive Personal Data such as information relating to your image, health (including information related to product usage and medical history), sexual life (and related behaviour) and biometrics collected during volunteer consumer research studies (such as facial expression recognition, heart rate and skin condition)
- demographic information; or
- any other Personal Data you voluntarily provide us with directly
Personal Data collected automatically
Personal Data collected this way may include:
- information about your (mobile) device or your type of browser
- information about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.
- whether you have opened e-mails sent by us to you
- the websites you have visited before arriving at one of our websites
- your IP address
- the hyperlinks you have clicked
- your username, profile picture, gender, networks and any other information you choose to share when using third party sites (such as when you use the “Like” functionality on Facebook or the +1 functionality on Google+)
- your MAC address
- information you choose to share by using social media tools incorporated in our websites or using your social media log-in details to access certain Scholl product sites or applications; and
- information you share with us about your location. Where we are required to do so by local law, we will only use that information where you have agreed that we can
Personal Data obtained from other sources
Lastly, we may also collect Personal Data about you from other sources. These other sources may include:
- our trusted business partners
- social media sites
- consumer research organisations
- credit reference agencies
- intermediaries that facilitate data portability; and
- other members of our group
Personal Data collected this way may include your interests such as hobbies and pets, consumer and market research data, purchase behaviour, publicly observed data or activities such as blogs, videos, internet postings and user generated content.
3. For which purposes, may we use your Personal Data
We use your Personal Data for our following business purposes:
- based on your contract with us, handling and managing your purchase, for instance to communicate to you with respect to your purchase, to process your payments, to deliver the purchased products and services, and to offer you the necessary customer service
- allowing you to participate in promotions, contests, surveys and polls
- allowing you to share information and ideas on our social media pages, forums, blogs and other communication channels, to participate in social sharing and to send messages to a friend through our Sites or the websites of our trusted business partners
- better understanding your needs in order to provide you with more relevant information, analysing and evaluating our corporate activities, testing, developing and evaluating new products and improving our existing products and services, conducting market research and audits, identifying user trends and examining the degree of effectiveness of our marketing campaigns and degree of satisfaction of our customers
- telling you about our products and services, and sending you promotional materials (such as announcements relating to new products, promotions, savings programs, joint promotions and other programs) relating to our brands and those of our carefully selected trusted business partners, subject to your consent to such marketing where required by local law
- managing our Sites, and tune the experience and content of our Sites to your previous activities on our Sites, in view of personalizing your experience when visiting our Sites
- responding to your requests or enquiries
- dealing with any product adverse events you report to us
- administering general record keeping; and
- meeting legal and regulatory requirements
4. Legal basis for processing
Your local law may require us to set out in this Privacy Notice the legal grounds on which we rely in order to process your Personal Data. In such cases, our use of your Personal Data is permitted by law because:
- it is necessary for our legitimate interests in the effective delivery of information, services and products to you and in the effective and lawful operation of our business (in each case provided such interests are not overridden by your rights)
- it is necessary for taking steps to enter into a contract with you for the products you purchase, or for carrying out our obligations under such a contract
- it is required to satisfy any legal or regulatory obligations that we are subject to; and
- in limited circumstances and if required by local law, you have agreed to us processing your Personal Data, such as when you opt in to marketing, or processing with your explicit consent in the case of Sensitive Personal Data, such as health information
We may create anonymous data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this anonymous data to analyse our products and services. We reserve the right to use such anonymous data for any purpose and disclose anonymous data to third parties, including but not limited to our research partners, in our sole discretion.
5. To whom we may disclose your Personal Information
Your Personal Data may be shared between the different companies and brands of our group, for the purposes set out in this Privacy Notice. As we have stated above, this Privacy Notice applies to all these companies’ and brands’ use of your Personal Data. For more information about us, our companies, our brands and our presence in your jurisdiction, please visit www.scholl.com.
Third party service providers
We may share your Personal Data with trusted third party service providers who work on our behalf, such as marketing agencies, market research companies, e-commerce fulfilment partners, software, data hosting and other IT service providers, merchants selling Scholl products, call centres, payment processors, etc. These third party service providers are required not to use your Personal Data other than to provide the services requested by us or otherwise in accordance with our instructions.
Other trusted third parties
We may also share your Personal Data with other trusted third parties, such as our business partners, advertisers (where we are permitted to do so) and data exchanges, so that we can offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to deliver customized content and advertising to you when you visit Scholl websites.
If another company acquires (part of) our company, business, or our assets, that company may acquire all or part of the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Notice. In the unlikely event of an insolvency, bankruptcy or receivership, your Personal Data may also be transferred as a business asset, subject of applicable law.
We may disclose your Personal Data if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent in light of our obligations under applicable law:
- in connection with any legal investigation
- to comply with relevant laws or to respond to court our authority orders, subpoenas or warrants served on us
- to protect or defend our rights in legal procedures; or
6. How we protect your Personal Information
We value the trust you place in us.
We have implemented appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.
When collecting or transferring Sensitive Personal Data we use a variety of additional security technologies and procedures to help protect your information.
The Personal Data you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.
When we process highly confidential information (such as credit card numbers) over the Internet, we protect it through the use of encryption.
7. Your choices regarding direct marketing
We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our products and services which we believe are useful for you, if you have consented (opted-in) to receive such messages via e-mail or any other electronic channel (where such opt-in is required under your local law).
If you do not wish to receive such communications anymore, you will always have the opportunity to "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see our contact information at “how to contact us” below).
Where permitted under applicable law, we may send you service messages identifying any updates to our Privacy Notice (even where you have opted out of receiving marketing messages from us).
8. Your rights
Depending on your location, you may have various rights in relation to your Personal Data. In particular, you may have the right to:
- request a copy of Personal Data we hold about you
- ask that we restrict the way in which we use your Personal Data
- ask that we update the Personal Data we hold about you, or correct any Personal Data that you think is incorrect or incomplete
- ask that we delete personal data that we hold about you (the “right to be forgotten”)
- withdraw consent at any time for the future to our processing of your Personal Data (to the extent such processing is based on consent)
- object to our processing of your Personal Data (including for direct marketing purposes); or
- request your personal data be transferred to you or another data controller (the “data portability” right)
In addition, in certain circumstances we may process your personal data through automated decision-making, including profiling. This may include segmenting and tailoring the data to enable us to match our communication and products to your perceived needs. In the case we process your Personal Data through automated decision-making, we will inform you about the logic involved, as well as the significance and the envisaged consequences of such processing for you. Depending on your location, you may be able to request not to be subject to automated decision-making, including profiling.
If you would like to exercise these rights or understand if they apply to you, please get in touch using the details set out at “how to contact us” below.
9. How long we retain your Personal Data
We will only retain your Personal Data as long as reasonably required for the purposes as set out in this Privacy Notice or otherwise to comply with legal or regulatory requirements applicable to us.
When your Personal Data is processed:
- for the performance of your contract with us, we retain your Personal Data for a period of 7 years following completion of a contractual order
- for meeting, legal and regulatory requirements, we retain your Personal Data as it is set out by the applicable law; and
- in all other cases, we process your Personal Data, depending on the type, for up to 2 years from the date of our last interaction with you
Most of our Sites are not directed towards children and we request that children below the age of 16 do not provide Personal Data through our Sites.
If you are the parent or legal guardian of a child under 16 who has registered on one of our Sites, or who you believe has otherwise provided Personal Data to us, please contact us using the details set out at “how to contact us” below to have the information deleted. Information voluntarily provided by children via e-mails, message boards, chat sessions etc. may be used by other parties to generate unsolicited e-mails. We encourage parents and legal guardians to inform children about how to use the Internet in a safe and responsible manner.
Depending on your location and where permitted by local law, we may collect information on your children in order to provide you with relevant information about our products and services.
11. Transfers to other countries
Your Personal Data may be transferred to and processed in other countries where laws governing the processing of Personal Data may be less stringent than the laws in your country (including jurisdictions outside the European Economic Area).
In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your Personal Data. Depending on the location of the Scholl entity exporting the relevant Personal Data, this adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request.
To the extent required and valid under your local law, you consent to your Personal Data being transferred and processed this way.
12. How to contact us
We welcome your feedback. If you have any comments, questions or complaints regarding this Privacy Notice or our processing of your Personal Data, or would like to exercise any of the rights set out at “your rights” above that are applicable in your location, you can contact us by sending an e-mail to DataProtection@scholl.com.
You may also write to us at:
Scholl Global Privacy Office, 2, Arlington Square, Downshire Way, Bracknell, RG12 1WA
If you are unhappy with the way we have handled your Personal Data or any privacy query or request that you have raised with us, you have a right to complain to your supervisory authority which is the UK's Information Commissioner's Office.
Their address is:
First Contact Team,
Information Commissioner's Office,
13. Changes to this Privacy Notice
This Privacy Notice was last modified on 01 March 2022. This document is a notice to you and not a contract between us. We may occasionally modify or amend it from time to time. When we make changes to this Privacy Notice, we will update the revision date at the top of this Privacy Notice. Where those changes are material, we will take steps to let you know. The new modified or amended Privacy Notice will apply from that revision date. Please always verify whether you have consulted the latest version of the Privacy Notice.