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.
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“).
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
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 from time to time, however, not more than once per week. 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 email@example.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 firstname.lastname@example.org.
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
Regent Mill, Fir St.,
M35 0HS England
Phone: +44 (0)161 947 3000
Fax: +44 (0) 161 682 1708
We shall respond to your request in accordance with the applicable legal provisions.
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
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, July 2018