We
take data protection and confidentiality very seriously and comply with
the applicable national and European data protection provisions. We
outline below the most important information concerning how we collect,
process and use data, including in particular, what information and
personal data we store, and what we do with it.
Some of the offers or services which we make available via
https://www.rayovac.eu/ may be covered by different provisions. These
additional provisions, such as prize draws or similar promotions, will
be referred to within the framework of our offer or service, and they
shall have precedence over the following provisions.
1. Controller
The responsible person for the collection, processing and use of your
personal data via this website, in accordance with the General Data
Protection Regulation (“GDPR”), is Spectrum Brands (UK) Limited, Regent
Mill, Fir St., Failsworth, Manchester, M35 0HS England (“Controller”,
Art. 4 (7) GDPR).
2. Collection, Processing and Use of Personal Data
2.1. Personal Data
Personal data is defined as any information relating to an identified or identifiable natural person (Art. 4 (1) GDPR).
This shall include, in particular, your name, email address,
telephone number, address, date of birth, as well as various inventory
data that you provide in the framework of an online order, a
registration, the creation of a customer account or a query submitted
via the contact form (hereinafter referred to as „Personal Data“).
Statistical data which we collect for technical reasons when you
visit our website, and which is anonymized and thus cannot be linked to
your person directly, shall not be covered by this Privacy Policy. Such
statistical data shall include information on your number of visits to
our website, the time that you spend on our website, the pages which you
visit, information on your browser(s), IP address, software and
hardware characteristics. This information shall be collected and
handled anonymously in order to obtain information on the use of our
website and optimise it accordingly.
2.2. Collection, Processing and Use of Your Data
In general, it is possible to use our websites without entering any
Personal Data. Insofar as our webpages collect any Personal Data, this
shall occur on a voluntary basis wherever possible.
In detail, we collect and process the following categories of Personal Data for the following purposes:
2.2.1. For our business relationship
We will collect and process your name, address, purchasing history
and similar required Personal Data to handle the business relationship
between us, for example to answer your query, to process the agreement
made with you, to deliver any ordered goods, to process payments or for
technical administration purposes. The legal basis for the processing is
Article 6 (1) lit. b GDPR as it is necessary for the performance of
contracts with you.
We will retain this Personal Data for the period of time that our
business relationship lasts. If there have not been transactions between
us for three years, we delete or anonymise your Personal Data, unless
we are required by law to store it for a longer period.
2.2.2. Create a profile for our database
When you contact us for the first time, we create a profile for you
in our database. All further Personal Data, which you subsequently
submit to us, e.g. via purchases or customer service contact, will also
be saved on your profile. The legal basis for this processing is Article
6(1) lit. b GDPR as it is necessary for the performance of contracts
with you.
We will retain this Personal Data for the period of time that our
business relationship lasts. If there have not been transactions or
customer service contacts by you for three years, we delete or anonymise
your Personal Data, unless we are required by law to store it for a
longer period.
2.2.3. Newsletter subscription & analysis of newsletter use
a) Subscription
If you subscribe to our email newsletter mailing list, when offered
on our website, we shall use the Personal Data submitted by you with
your consent for sending email newsletters to you on a regular basis,
however, not more than once every calendar quarter. You must submit your
email address in order to register. Any further information, such as
your gender, first name and last name shall be submitted on an entirely
voluntary basis and used in order to personally address you in the
newsletter. The newsletters will contain current offers, news and
information about our products as well as general advice and information
regarding matters revolving around our products. The legal basis for
this processing is your consent pursuant to Article 6(1) lit. a GDPR.
We will retain your Personal Data for this purpose either (i) until
you unsubscribe or (ii) for a maximum of 18 months not opened any
newsletter. We will then delete or anonymise your Personal Data, unless
we are required by law to store it for a longer period.
You may withdraw consent by unsubscribing from our email newsletters
at any time, without reason and with immediate effect. You can
unsubscribe via the unsubscribe link at the bottom of our email
newsletters, by using our contact form, or by sending an email to
dsr@eu.spectrumbrands.com.
b) Analysis of newsletter use
We continuously seek to improve our service. With this in mind, we
carry out an evaluation of the sent email newsletters, e.g. whether the
submitted email addresses are available, whether the newsletter has been
opened, which links in the newsletters have been used and whether there
is any response or return ((automatic) reply, error message etc.). The
legal basis for this processing is your consent pursuant to Article 6
(1) lit. a GDPR.
We will retain your Personal Data for this purpose for two years. We
will then delete or anonymise your Personal Data, unless we are required
by law to store it for a longer period.
2.3. Consent of minors
Persons aged under 16 may not submit any Personal Data to us without the prior consent of their parents or legal guardian.
2.4. Where you consent: Right to withdraw consent
Where your consent is the legal basis for the processing of your
Personal Data, you can withdraw your consent at any time without
reasons. Please note that withdrawing your consent will not affect the
lawfulness of the processing before the withdrawal.
3. How we share your Personal Data with third parties
Your Personal Data shall only be transferred to third parties in the following cases:
- To our affiliated companies within the Spectrum Brands group or
to local distribution partners, depending on your indicated location, in
connection with your use of the RAYOVAC website, your request to us or
our business relationship with you;
- To our IT agencies which provide IT services to us and which
process such data only for the purpose of such services (e.g., hosting
or IT maintenance and support services, newsletter system); and
- To courts, arbitration bodies, law enforcement authorities,
regulators or attorneys if necessary to comply with the law or for the
establishment, exercise or defense of rights or legal claims.
Insofar as we contract other companies to carry out tasks on our
behalf within the framework of a data processing agreement and forward
your Personal Data for this purpose, said company or companies shall be
required to protect your Personal Data and to use the latter only for
the specific purpose outlined in the agreements with these processors.
In cases we transfer, depending on your indicated location, data to
countries outside the EU/EEA, we transfer personal data to external
recipients in such countries only if the recipient has sufficient
safeguards required by law such as EU Standard Contractual Clauses or is
certified under the Privacy Shield.
You may request further information, such as copies of the respective
safeguards, about the safeguards implemented in relation to specific
transfers by contacting dsr@eu.spectrumbrands.com.
4. Your rights concerning your Personal Data
If certain requirements are fulfilled, you have the following rights:
- Request access to the Personal Data that we process about you,
- Request rectification of your Personal Data,
- Request erasure of your Personal Data,
- Request restriction of Processing of your Personal Data,
- Object to the Processing of your Personal Data,
- Request to receive your Personal Data in a structured, commonly used and machine-readable format (right to data portability), or
- Withdraw any future consent with future effect.
- Not to be subject to a decision based solely on automated processing, including profiling.
You may contact us to claim your rights as follows:
Spectrum Brands (UK) Limited
DSR Request
Regent Mill, Fir St.,
Failsworth,
Manchester,
M35 0HS England
Phone: +44 (0)161 947 3000
Fax: +44 (0) 161 682 1708
dsr@eu.spectrumbrands.com
We shall respond to your request in accordance with the applicable legal provisions.
5. Cookies
To learn more about our policy on cookies, click here[A1] to read our Cookie Policy.
6. Data Security
We do our utmost to store your Data using all the technical and
organisational possibilities at our disposal to prevent third parties
gaining access to it.
All Data is stored on servers with the highest security standards to
protect against any attempts by third parties to access the Data.
7. Our Data Protection Officer
If you have questions with regard to this Privacy Policy or to our
processing of your Personal Data, please contact our Data Protection
Officer:
gdpr@eu.spectrumbrands.com
8. Your right to lodge a complaint
If you think that the processing of Personal Data by us violates data
protection laws, you have the right to lodge a complaint with the
competent supervisory authority.
© Spectrum Brands (UK) Limited, May 2018