Privacy Notice - www.helenoftroy.com/emea-en
I. Kaz Europe Sarl – Privacy Notice – 15/05/18
This policy describes Kaz Europe Sarl (referred to as „Kaz Europe”, “we“, „us“ or „our“) use of your data, and applies to the website www.helenoftroy.com/emea-en and its subpages.
We value the trust you place in Kaz Europe. We want to ensure you that we take the protection of your privacy and your personal data very seriously, and that we process your data in accordance with applicable data protection laws, particularly in compliance with the EU General Data Protection Regulation (Regulation (EU) 2016/679 referred to as “GDPR”).
Below we explain to you which personal data we gather about you in connection to this website, how we use it, and the safeguards we have in place in order to protect it.
II. What data do we collect? For what purposes, and on what legal basis do we use your data?
We gather personal data needed to provide superior service, communicate offers on merchandise and services that we believe will be of interest to you, and to administer our business. In order to best serve you, we may gather information from you in a few instances.
You can provide your personal data voluntarily. However, please keep in mind this data may be required to provide services or marketing content.
You can provide us with personal data if you subscribe to our email program (information such as your name and e-mail address), choose to provide us with preference information (such as interests, product preferences, and items purchased), send us an inquiry, comment or complaint (information such as your name and e-mail address), or when you enter a sweepstakes or promotion (information such as name, address and telephone number).
Additionally, in order to provide you with services designed to meet your needs, we may collect demographic information (such as number of household members, age, and gender), and purchase preference information. We use this information to customize your experience on our website and to provide you with the most relevant products and services.
We would like to give you some detailed information about personal data that we may process, purpose of the data and legal basis for processing:
|Personal data||Purposes of processing||Legal basis of processing|
|Date and time of the request, Name of the requested file, Page from which the file was requested, Access status (transfer file, file not found, etc.), web browser and operating system used, complete IP address of the requesting computer, transferred amount of data||Operating website, technical necessity, web analytics and statistics to monitor, improve and protect our products, content, services and websites; providing website customized experience; providing tailored adds; remarketing; providing where to buy solution; creating user profile based on your activity; monitoring performance of marketing campaigns||Our legitimate interest according to Article 6 (1) point f) of GDPR.|
|Your name, gender, email address, product interest||Sending email Newsletter||Your consent (Art. 6 (1) point a) GDPR or for existing customers we may also base our processing on the so-called soft opt-in/legitimate interest according to Article 6 (1) point f) of GDPR.|
|Your name, your gender, your email address, your location, your interests, product preferences, purchased items||Marketing of our products||Your consent according to Article 6 (1) point a) of GDPR.|
|Your name, your gender, blog address, your location, email address, product of your interest||Providing the partner program||Performing the contract on the partner program according to Article 6 (1) point b) of GDPR.|
|Your name, email address, phone number||Responding to your inquiries, comments and complains||Our legitimate interest (maintaining our relationship with customers) according to Article 6 (1) point f) of GDPR or (in case the response relates to a contract with you the performance of this contract [on the partner program] according to Article 6 (1) point b) of GDPR.|
|Your name, address and telephone number||Carry out sweepstakes and promotions that you entered into||Your consent according to Article 6 (1) point a) of GDPR.|
|Your personal data in general (only as required)||Complying with applicable laws and protection of our legitimate business interests and legal rights including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation)||Our legitimate interest according to Article 6 (1) point f) of GDPR or the respective laws requiring us to process your personal data (see Art. 6 (1) point (c) GDPR).|
III. What data do we share and with whom and where?
We may share your customer information with Kaz Europe's affiliates and trusted service providers that need access to your information to provide operational or other support services. To ensure the confidentiality and security of your information, service providers must agree to safeguard your information in strict compliance with our policy.
We will share your personal data with the following affiliates/third parties (acting as data controllers):
|Affiliate/Third Party||Description of transfer/purpose||Third Country Transfers (outside EEA)|
|HOT (UK) Limited||Marketing purposes for which we received your consent.||None|
Personal data will also be shared with the following third party service providers (acting as data processors), who will process it on our behalf and subject to a data processing agreement as required by law:
|Affiliate/Third Party||Description of transfer/purpose||Third Country Transfers (outside EEA)|
|Amazon Web Services, Inc.||Hosting of website in data centre in Ireland||Privacy Shield|
|Google, Inc||Website analytics services||Privacy Shield|
In the event that the business is sold or integrated with another business, your details may (subject to the applicable laws) be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules (see tables above). A copy of the relevant mechanism can be provided for your review on request to privacyEU@kaz.com.
IV. How can you “opt out” of receiving promotional e-mails?
If you do not wish to receive promotional offers and/or you want to withdraw your consent you can opt out, to do so contact us at Product Support and your e-mail address will be removed from our marketing list.
V. What rights do you have in relation to your data?
You have the right to ask us:
- for access to and a copy of your personal data that we hold on you (Art. 15 GDPR)
- for a copy of the personal information you provided to us and to provide it to you or send to a third party in a commonly used, machine readable format (Art. 20 GDPR)
- to update or correct your personal data in order to make it accurate (Art. 16 GDPR)
- to delete your personal data from our records in certain circumstances Art. 17 GDPR)
- to restrict the processing of your personal data in certain circumstances (Art. 18 GDPR).
And you may also:
- object to us processing your personal data in certain circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing - Art. 21 GDPR)
- withdraw your consent at any time, where we are using your personal data with your consent. This will not affect our use of your personal data prior to the withdrawal of your consent.
You can exercise any of your rights, in particular withdraw your consent, by contacting us at privacyEU@kaz.com. We may need to verify your identity in order to fulfil your request. When addressing us, please always provide your name, address and/or email address as well as information about your request.
Please note that fulfilling some of the above-mentioned request may depend on the occurrence of circumstances provided in applicable law, particularly in GDPR.
When you have unresolved concerns, you also have the right to complain to a data protection authority, in particular data protection authority in the Member State of your habitual residence or place of work.
VI. How long will my personal data be retained?
We will retain your personal data only for limited period of time needed to fulfil purposes of processing mentioned in table above. After that time your personal data will be erased. If we process your personal data based on your consent we will retain your personal data for limited period of time needed to fulfil purposes of processing.
Where we enter into a contract with you, we will keep your information for the duration of the contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. The criteria to determine the storage period are statutory and contractual requirements, the nature of our relationship with you, the nature of the data concerned, technical necessities. Laws may require us to hold certain information for specific periods.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
Where we process personal data for site security purposes, we retain it for 60 days.
In other cases, we may retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business.
VII. How we ensure that your information is secure?
Kaz Europe and its affiliates will maintain practices and procedures designed to ensure the security, integrity and confidentiality of customer information. We restrict and limit access to customer information only to those of our employees or authorized service providers who require it to carry out their business functions, and educate our employees about safeguarding customer information, and preventing its unauthorized access, disclosure, or use.
Through the use of computer “cookies” (small pieces of information that are stored by the browser on your hard drive), we collect data, such as your IP address, browser type, domain name, and specific Kaz Europe web pages through which you click. Cookies that are configured by us do not contain any personally identifying information, such as your name, or sensitive information, such as your credit card number. This data is collected automatically, and utilized in aggregate to help us look for trends so that we can improve our website and your Kaz Europe experience.
Cookies also allow us to recognize you when you return to our site, and to provide you with a customized experience that we feel will be of value to you. Most web browsers allow you to exercise control over cookie files on your computer by erasing them, blocking them, or notifying you when such a file is stored. Please take a look at your particular browser for instructions on this function. If you do elect to disable the Kaz Europe Cookies, please note that you may not be able to take full advantage of the personalized experience at Kaz Europe.
For more information, please see our Cookies Policy
IX. If you have any questions about your data
The data controller for this processing is Kaz Europe Sarl, Place Chauderon 18, 1003 Lausanne, Switzerland
If you have any questions about the processing of your personal data, please feel free to contact us at +44 (0) 115 965 7449.