Last modified on August 2017
By "Personal Information" (in some countries referred to as "personal data" or "personally identifiable information") we mean any information relating to an identified or identifiable natural person 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. Personal Information may also include sensitive information (e.g. any information about your racial or ethnic origin, political opinions, religious beliefs, sexual orientation, health information etc.). We generally do not wish to be informed of a person’s sensitive information. We will not collect sensitive information unless we obtain your express consent to do so. 2
- our official social media pages;
- our e-mails;
- 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".
We only collect, use, disclose or otherwise process your Personal Information where it is fair and lawful to do so.
If you do not wish to provide your Personal Information to us, we may not be able to provide you with the products and services you have requested.
3. How do we obtain your Personal Information?
You have the option of providing information to us anonymously, unless we consider that it would be 4 impractical for us to deal with you anonymously. For example, you have the option of providing us with only a telephone number or email, or a telephone number and email accompanied by a pseudonym, or by only providing an email or telephone number. However a consequence of not providing your name or address may be, amongst other things, that certain services may not be available to you, or that you will not be able to be awarded a prize if you are a prize winner in a competition or promotion which is being run by us.
Personal Information obtained from you directly
Firstly, we may obtain your Personal Information 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, etc.
Personal Information collected this way may include:
- e-mail address;
- user name;
- telephone number;
- credit card or other payment information;
- date of birth;
- product purchase and usage information;
- household information;
- user-generated content, posts and other content you submit to our Sites;
- sensitive information such as information relating to your health and sex life;
- employment history and educational qualifications;
- complaint details; and
- any other Personal Information you provide us with directly.
Personal Information collected automatically
Personal Information 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;
- information you choose to share by using social media tools incorporated in our websites; and
- if you have consented to this, your precise location data.
We may also analyse website traffic to identify what visitors find most interesting so we can tailor our websites accordingly.
From time to time, we may also use third party analytics services such as Google Analytics Advertising Features. We may use this technology to obtain an additional set of user data such as the gender, and/or age bracket of the website user which does not identify the user. We may also use these technologies to deliver relevant promotional and other targeted information to you on our Sites and other third party websites based on your use of our Site.
We will never use this technology to merge any information that identifies you with anonymised information collected through any Google advertising product or feature unless we have obtained your prior consent.
Where you have provided your Personal Information and explicitly consented to receiving digital communications from our brands, we may include you in our targeting of Custom Audiences (e.g. Facebook Custom Audiences of Google Customer Match).
You may request that you be removed from this level of targeting by contacting us directly (see contact details below).
Each third party advertising partner (e.g. Facebook, Google, AdRoll, etc) offers an opportunity for you to opt out of these features or this level of targeting. For example, you may opt-out of the Google Analytics Advertising Features by changing your settings in Ad Settings, Ad Settings for mobile apps, using the Google Analytics Opt-Out Browser Add-on, or any other means available.
Personal Information obtained from other sources
Lastly, we may also collect Personal Information from other sources, such as our trusted business partners.
Personal Information collected this way may include income level, your interests such as hobbies and pets, consumer and market research data, purchase behavior, publicly observed data or activities such as blogs, videos, internet postings and user generated content.
4. For which purposes we may use your Personal Information
We may use your Personal Information for our business purposes such as
- 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, developing 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;
- with appropriate permission, 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 selected business partners;
- managing our Sites, and tune the experience and content of our Sites to your previous activities on our Sites, in view of personalising your experience when visiting our Sites;
- responding to your requests or enquiries, including, but not limited to, for recruitment/employment purposes and consumer enquiries or complaints;
- verifying your identity;
- contacting you to ensure your Personal Information is up to date and accurate; and
- meeting legal or other regulatory obligations imposed on us.
We do not sell your Personal Information. 7
We may create anonymous data records from Personal Information 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
Third party service providers
We may share your Personal Information with third party service providers who work on our behalf, such as marketing agencies, recruitment agencies, market research companies, e-commerce fulfilment partners, software providers, merchants selling RB products, payment processors, information technology service providers, customer complaints and enquiries handling, payroll software and service providers and corporate services agencies etc. These third party service providers are required not to use your Personal Information other than to provide the services requested by us. We do not share your Personal Information with any third party that intends to use it for direct marketing purposes, unless you have provided specific consent in relation to this.
We may disclose your Personal Information if we believe in good faith that such disclosure is necessary:
- in connection with any legal investigation;
- to comply with relevant laws or to respond to court orders, subpoenas or warrants served on us;
- to protect or defend our rights; and
We only disclose your sensitive information for the purposes for which you gave it to us or for directly related purposes you would reasonably expect or if you agree.
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 Information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.
When collecting or transferring Personal Information we use a variety of additional security technologies and procedures to help protect your Personal Information.
The Personal Information 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 provided specific consent to receive such messages via e-mail or any other electronic channel.
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 contact information below).
8. How to access, correct or delete your Personal Information
We strive to keep your Personal Information accurate and up-to-date.
We provide you with reasonable access to your Personal Information and the possibility to review this, and request correction and deletion where appropriate.
In order to protect your privacy, we will take reasonable steps to verify your identity before granting access to your Personal Information.
The Personal Information we hold about you can be consulted and modified by following the instructions on the Site concerned or by contacting us directly (please see contact information below). We will respond to your access request within 30 days, and in accordance with any terms specified by applicable law.
9. How long we retain your Personal Information
We will only retain your Personal Information as long as reasonably required for the purposes as communicated above.
Most of our Sites are not directed towards children and we request that children below the age of 18 do not provide Personal Information through our Sites.
If you are the parent or legal guardian of a child under 18 who has registered on one of our Sites, or who you believe has otherwise provided Personal Information to us, please contact us directly (please see contact information 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.
We may ask you information on your children in order to provide you with relevant information about our products and services.
11. Disclosure of Personal Information overseas
Your Personal Information may be transferred to and processed in other countries including Australia, United Kingdom, United States of America, Ireland, France and Germany.
We have implemented strict procedures and controls in order to ensure that your Personal Information is protected adequately regardless of the country where it is stored or otherwise processed. We will take all reasonable steps necessary to ensure that any Personal Information transferred overseas is kept securely and in accordance with the NZPPs by the overseas entity.
By using our Sites and Services, you consent to your Personal Information being transferred and processed this way.
Web traffic information is disclosed to Google Analytics when you visit our websites. Google stores information across multiple countries. For further information see Google Data Centres and Google Locations.
When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your Personal Information overseas.
13. How to contact us
You can contact us by sending an e-mail to email@example.com, by phone on +64 9 839 0200 during office hours or by sending a letter to
Attention: Privacy Officer
Reckitt Benckiser (New Zealand) Limited
Private Bag 93523
Takapuna, Auckland 0740