Last update 2018-09-28
PRIVACY POLICY
This privacy policy applies only to the websites controlled by Reckitt Benckiser LLC ("RB") where this privacy policy is posted or referenced (collectively, the "Sites"). This privacy policy does not pertain to other information that is collected offline or to information that is posted or provided by third parties.
BY USING THE SITES, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITES.
Sections
A. Information Collected
This privacy policy applies only to information collected on the Sites and does not apply to information collected by RB through any other means.
We collect two types of information from visitors to the Sites: (1) Personally Identifiable Information; and (2) Non- Personally Identifiable Information, such as your IP address or cookies.
(1) Personally Identifiable Information
"Personally Identifiable Information" is information that identifies you personally, such as your name, address, telephone number, email address, or company name. RB collects and stores the personally identifiable information that you have provided to us on the Sites, including as follows::
We may collect your first and last name and product or service details if you contact us with a question related to our products or services; We may collect your first and last name, mailing address and billing information if you purchase a product or service on the Sites; We may collect registration details about a product that you purchase from RB and this information may be tied to your name and mailing address; We may collect your first and last name, mailing information, email address and billing information if you download information from a Site; We may collect your name, email address or phone number if you contact us with a question; We may collect your first and last name, date of birth and email address if you choose to participate in a contest or sweepstakes; and/or We may collect your name and mobile phone number if you consent to receive autodialed and/or pre-recorded telemarketing messages from or on behalf of us at your mobile number. If you do not want RB to collect your personally identifiable information, please do not provide it to us.
(2) Non-Personally Identifiable Information
"Non-Personally Identifiable Information" can be technical information or it can be demographic information, such as your age, location, gender or interests. Non-personally identifiable information does NOT identify you personally. Here are some examples of the non-personally identifiable information that is collected via the Sites:
Internet Protocol (IP) address -- Your IP address is a number that lets computers attached to the Internet know where to send you data -- such as the webpages you view.
Cookie -- A "cookie" is a small text file that may be used to collect information about your activity on the Sites. For example, when someone visits a page within the Sites, a cookie is placed on the user's machine (if the user accepts cookies) or is read if the user has visited the Sites previously. Cookies may also be used to track users across the Web. We use the information we collect from cookies for marketing and product planning purposes. Collected data may also be shared, in aggregate form, with third-parties (e.g., dealers, marketers, distributors, Shopify, and Google Analytics). We do not currently honor any “do-not-track” signal sent by browsers. However, you may opt-out of targeted advertising from National Advertising Initiative members by visiting http://www.networkadvertising.org/choices/. You may also set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users to our Sites. Additionally, some of the cookies we use may be flash cookies or Adobe cookies. While they are harmless, they may contain non-personally identifiable information and depending on your browser these cookies may not normally be deleted when your cookies are deleted. Please check your browser to determine where these types of cookies are stored and how they may be deleted.
Some cookies may, when combined with other information, constitute Personally Identifiable Information. These cookies are subject to the same protections found in this Privacy Policy. You can find more information about our use of cookies in our Cookie Policy.
Cookies -- Third-Party Online Advertising. To understand your interests and deliver advertisements that are tailored to your interests, we may work with third parties that use their own cookies, web beacons, and other technologies to collect Information about Site Visitors’ online activities, either on our Sites and/or other websites across the Internet. These third parties include advertisers and ad networks that may collect information about when you view or interact with one of their advertisements and may collect information regarding your activities on our Sites and your online activities over time and across different websites. Like most advertisers, we work to place our advertisements where we think they will be most interesting and relevant to the recipient. One way we do this is by allowing ad networks to place their own cookies when an individual visits our Sites. This enables the ad network to recognize individuals who have previously visited our Sites. Then, if the ad network has purchased ad space on a third-party website, and recognizes that same individual visiting that third-party website, the ad network can deliver one of our advertisements, knowing that this individual has already expressed interest in our Sites, products, and/or services by visiting our Sites. To learn more about third parties who collect Site Visitor Information, please review our Cookie Policy.
Web Beacons (also known as "clear gifs," "web bugs" or "pixel tags") -- "Web Beacons" are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain pages of the Sites and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on web pages.
Product Information -- We may collect registration information or other details about your product or service. Unless this information is tied to your name or address, it is not considered personally identifiable. We may collect the above non-personally identifiable information from all visitors to our Sites. If you do not want RB to have access to this information, please do not visit our Sites.
B. Use of Information Collected Via the Sites
(1) Personally Identifiable Information
We use your personally identifiable information that is collected on these Sites primarily for the following purposes:
To deliver services; To alert you to special offers, updated information and other new products or services from RB, or other third parties, or to forward promotional materials to you (subject to your right to opt out of receiving such alerts or promotional materials as outlined in Section G below); To complete a transaction or service requested by you; To ensure the Sites are relevant to your needs; To help us create and publish content most relevant to you; To notify you about a material change to this privacy policy or our Terms of Use, if necessary; To allow you access to limited-entry areas of the Sites; and To contact you in response to sign up forms such as Contact Us or other inquiry. In addition, if you email us a question, we may use your email address to process your request and respond to your question. Also, if you are entering a sweepstakes or contest, we may use your personally identifiable information in order to fulfill the terms of that promotion.
(2) Non-Personally Identifiable Information
Non-personally identifiable information is used as described above and in other ways as permitted by applicable laws, including combining non-personally identifiable information with personally identifiable information.
C. Sharing and Disclosure of Information
(1) Personally Identifiable Information
We may share or disclose your personally identifiable information in the following instances:
To our parent company, subsidiaries and affiliates in order to better serve you. RB may have to share your data with these parties in order to provide you with services that have been requested by you, or so that we can ensure our services and products are meeting your needs.
To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on RB's behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the personally identifiable information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Sites will have access to users' personally identifiable information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personally identifiable information to us.
To complete your purchase. If you choose to make a purchase on the Sites, we may collect from you your credit card number, billing address and other information related to such purchase, and we may use such collected information in order to fulfill your purchase. We may also provide such information, or other personally identifiable information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).
To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process or other government requests served on us (including in response to lawful requests by public authorities to meet national security or law enforcement requirements), protect and defend our rights or property, including the rights and property of RB, or act in urgent circumstances to protect the personal safety of our end users.
To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
To protect against potential fraud, we may verify with third parties the information collected from these Sites. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen.
Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personally identifiable information to any third parties.
(2) Non-Personally Identifiable Information
We use non-personally identifiable information collected on the Sites in the manner disclosed above, in the Section A (2). We may share this non-personal information with our fulfilment partners for research and statistical purposes.
D. Google Analytics
Our Sites use Google Analytics, a web analytic service provided by Google, Inc. Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of our Sites. Google Analytics uses javascript ad cookies to help us analyze how visitors use our Sites. For more information on Google Analytics cookies, please visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites, please visit http://tools.google.com/dlpage/gaoptout. This allows you to download and install a Google Analytics cookie-free web browser referred to as the “Google Analytics Opt-out Brower Add-On.”
Our Sites have implemented and use display advertising, and we utilize Google Analytics to implement specific features called (i) Remarketing, and (ii) Demographics and Interest Reporting. These are features of Google’s Advertising / AdWords that allow us to optimize the delivery of ad content specifically targeted to a visitor’s interests based upon previous visits to our Sites. They also provide us with information about the age and gender of our visitors, along with the interests they express through their online travel and purchasing activities.
If you’d like more information about Remarketing in Google Analytics, please visit https://support.google.com/analytics/answer/2611268?hl=en. For more information about Demographics and Interest Reporting, please visit https://support.google.com/analytics/answer/2799357?hl=en.
If you would like to opt-out of Google Analytics for display advertising, you may do so by using the Ads Preferences Manager at https://adssettings.google.com/authenticated?hl=en. Alternatively, you can disable the use of cookies for interest-based advertising via the advertising network initiative, by following the instructions at http://optout.networkadvertising.org/?c=1#!/.
For more information about how we use cookies through Google Analytics, please read our Cookie Policy.
GTM is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behavior; to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our Sites to include the Google Analytics tracking tool.
E. Collection and Use of Information from Children Under the Age of 13
RB does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to use the Sites. If you are under 13 please do not attempt to register on the Sites or send us any Personal Information.
F. International Transfer of Information
If you choose to provide us with personally identifiable information, RB may transfer that information to its affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world.
G. Opt-Out
From time to time, we communicate with users who subscribe to our services via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional and you have consented to receiving such e-mails by providing your email address.
However, we provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services and products offered on the Sites. For e-mails, the opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where personally identifiable information is collected or by contacting us. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until we have had time to make the opt out effective. You also may opt-out of receiving such emails by clicking on the "unsubscribe" link within the text of the email. For text messages, should you choose to “unsubscribe” or stop receiving such messages, you can contact us directly at consumer.relations@rb.com or reply with the message “STOP” to a message after it is received. Further, you hereby confirm consent to receiving a confirmatory message in response to your STOP request. Message and data rates may apply.
H. Forums, Chat Rooms and Other Public Posting Areas
Please note that any information you include in a message you post to any product review board, chat room, forum or other public posting area is available to anyone with Internet access. If you don't want people to know your e-mail address, for example, don't include it in any message you post publicly
I. Third Party Web Sites
This statement applies solely to information collected on the Sites. The Sites may contain links to other web sites. We are not responsible for the privacy practices or the content of these other web sites.
With respect to purchase transactions through the commerce solution which is accessible through the Sites, end users may be required to provide personally identifiable information (including credit card information) directly to a third-party retailer in connection with the sale of products through the Sites, and any information so disclosed to such third party shall be governed by such third party’s privacy policy.
J. Assignment
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personally identifiable and non-personally identifiable information collected via the Sites.
K. Changes to this Privacy Policy
We reserve the right to change this privacy policy from time to time in our sole discretion. When we do, we will also revise the "last update" date at the bottom of this privacy policy.
L. Security
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to RB is done at your own risk.
Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personally identifiable information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
M. Your Rights
If you are from the European Union or Switzerland and wish to obtain access to the personal information that we hold about you, or to correct, amend, update or delete such information, please contact us at the address below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timescales required by law.
N. Governing Law / Venue / Forum
This Agreement shall be governed by the laws of the State of New Jersey and by the federal laws of the United States, excluding their conflicts of laws provisions. Without prejudice to the procedure for making inquiries or complaints under the Privacy Shield Framework, as outlined below, all disputes, controversies and disagreements between the parties arising out of or related to this privacy policy shall be exclusively submitted for, resolved and finally settled by, binding arbitration. The arbitration shall be conducted by three (3) arbitrators exclusively in Morris County, NJ, in accordance with the Commercial Arbitration Rules of the American Arbitration Association. The Parties waive any objection that might be made on the ground that such venue may be in an inconvenient forum.
O. Contacting RB
If you have any questions about this privacy policy or our privacy practices, please contact us at consumer.relations@rb.com or write to us at:
Reckitt Benckiser LLC
399 Interpace Parkway
Parsippany, NJ 07054-0225
Attn: Consumer Relations
All information you provide in any written communication will also be covered by this policy.
P. Additional Information for Non-U.S. Residents
This Site and material provided on this Site are solely for promoting products, programs, and business operations within the United States. If you provide Personally Identifiable Information to us (including through the Contact Us section), it may be transferred to and processed on computers in the United States. and other countries. Do not provide us with your Personally Identifiable Information if you do not want your Personally Identifiable Information to be transferred to the United States. or to other countries, or if the laws in your country restrict these types of transfers. Your provision of Personally Identifiable Information to us will be handled in accordance with this Privacy Policy. Your provision of Personally Identifiable Information to us through this Site means that you agree to this Privacy Policy.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD
RB complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Economic Area (EEA) (which includes the member states of the European Union plus Iceland, Liechtenstein and Norway) and Switzerland to the United States. In doing so, RB has certified that, in respect of all personal data it receives from the EEA and Switzerland, it will adhere to the Privacy Shield Principles of: Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the terms in this policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To access the Privacy Shield List, and to find details of RB's certification, please visit www.privacyshield.gov.
RB's participation in the Privacy Shield applies to all personal data that is subject to this privacy policy and is received from the EEA and Switzerland. RB will comply with the Privacy Shield Principles in respect of such personal data. Please note that some Non-Personally Identifiable Information (as described above) that originates from the EEA or Switzerland may be classed as personal information for the purposes of Privacy Shield Framework (e.g., IP addresses; cookie IDs and other online identifiers; and profile information that is not necessarily linked to a named individual).
Where RB transfers personal data from the EEA or Switzerland to its third-party agents and service providers, it will require such third parties to process the information only for the purposes described in this privacy policy and to provide the same level of protection for the information as required by the Privacy Shield Principles. RB remains responsible and liable for onward transfers under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless RB proves that it is not responsible for the event giving rise to the damage.
If you believe that RB is processing your personal data within the scope of its Privacy Shield certification, you may direct any inquiries or complaints concerning its Privacy Shield compliance in the following ways:
(1) In the first instance, please send your inquiry or complaint to consumer.relations@rb.com or by writing to one of the following mailing addresses:
Reckitt Benckiser LLC
399 Interpace Parkway
Parsippany, NJ 07054-0225
Attn: Consumer Relations
RB Global Privacy Office
Turner House
103-105 Bath Road
Slough, United Kingdom
SL1 3UH
RB will respond within forty-five (45) days.
(2) Whether you are from the EEA or Switzerland, if you are not satisfied with RB's response, or for complaints that cannot be resolved with RB directly, RB has committed to refer unresolved privacy complaints under the Privacy Shield via the American Arbitration Association – International Centre for Dispute Resolution, an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by us, please visit: http://go.adr.org/privacyshield.html for more information and to file a complaint directly with the AAA.
(3) If you are from Switzerland and you believe that your information has not been processed in compliance with the Swiss-U.S. Privacy Shield Framework, you may raise your concern with the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). RB will cooperate with the FDPIC and comply with the information and advice provided to it by the FDPIC in relation to unresolved complaints. For more information about the FDPIC, please visit https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html.
(4) Your complaint can be made or referred to the U.S. Department of Commerce or the U.S. Federal Trade Commission for further investigation.
(5) If you do not resolve your complaint via one of the above routes, a binding arbitration option will also be made available to you to address such residual complaints under certain conditions. To find out more about the Privacy Shield's binding arbitration scheme, please visit https://www.privacyshield.gov/article?id=G-Arbitration-Procedures.
RB's commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
YOUR CALIFORNIA PRIVACY RIGHTS
Beginning on January 1, 2005, California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding RB's disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please contact us:
Reckitt Benckiser LLC
399 Interpace Parkway
Parsippany, NJ 07054-0225
Attn: Consumer Relations
Dates
Effective Date: September 30, 2016
Last Updated: September 17, 2018
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