Last update 2019-12-19
Effective Date: December 1, 2019
K. Do Not Sell
A. Personal Information Collected
We may collect personal information about you in a variety of ways, including directly from you as well as automatically through your use of Our Sites or Services.
(1) Information We Collect Directly From You.
We may collect the following personal information directly from you:
· If you create an account with us (which may be required to access certain features of Our Site and Services), we may collect your first and last name, email address, preferred password, and if you agree to receive promotional/marketing emails from us;
· In connection with your account and, at your option, we may collect your date of birth, gender, interests, mailing address, and answers to survey questions regarding goods and services that may be of interest to you;
· If you purchase a product or service via Our Sites, we may collect your first and last name, email address, mailing address, and billing information;
· If you contact us with a question related to our products or services, we may collect your first and last name, email address or phone number, and product or service details;
· If you choose to participate in a contest or sweepstakes, we may collect your first and last name, date of birth, and email address; and/or
· If you apply for a job, we may collect your first and last name, email address, mailing address, and your education and work history, and other information you may provide to us when applying.
(2) Information We Collect Automatically.
We may automatically collect the following personal information about your use of Our Sites or Services through cookies, web beacons, and other technologies:
· your domain name;
· your device ID;
· your browser type and operating system;
· web pages of Our Sites you view as well as sites you may visit directly before arriving or on leaving Our Sites;
· links you click;
· your Internet Protocol (IP) address;
· location information of your device;
· the length of time you visit Our Sites and/or use our Services;
· and the referring Uniform Resource Locator (URL), and the webpage that led you to Our Sites.
We may combine this information with other information that we have collected about you. Please see the section “Cookies” below for more information.
(3) Use of Information Collected Via Our Sites
We may use your information, including your personal information, for the following purposes:
· To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
· To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using Our Sites or Services.
· For marketing and promotional purposes. For example, we may use your personal information, such as your email address, to send you newsletters, marketing emails, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the personal information that we collect to assist us in advertising our Services on third party websites.
· To better understand how users access and use Our Sites and Services, both on an aggregated and individualized basis, in order to improve Our Sites and Services and respond to user desires and preferences, and for other research and analytical purposes.
· To protect us and others, including as necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats to the safety of any person or as necessary to comply with law
· To administer contests, petitions, and sweepstakes.
· To administer our rewards program.
B. Sharing and Disclosure of Information
We do not sell or rent your personal information to third parties. From time to time, we may share your information, including personal information, as follows:
· Affiliates. We may disclose the personal information we collect from you to our affiliates or subsidiaries (see www.rbnainfo.com); however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
· Service Providers and Vendors. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, such as order processing and fulfillment, customer service, research, administration of contests and sweepstakes, sending communications, and performing data analytics.
· Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
· In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
· Aggregate, Anonymized, and De-Identified Information. We may share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
We will require these third parties to maintain the confidentiality of your personal information. If you are a California resident, we will not authorize these third parties to use the personal information we provide for their direct marketing purposes (as such term is defined in the California “Shine the Light” Law, California Civil Code §§ 1798.83), unless we have explicitly given you the option to opt-in or opt-out of such disclosure.
We do not authorize these third parties to use your personal information for purposes other than for which it has been provided, and do not authorize these third parties to disclose that information to unauthorized parties or use that information for their direct marketing purposes.
C. Collection and Use of Information from Children Under the Age of 13
Our Site and Services are not intended or directed to children. You may not use Our Site and Our Services if you are under the age of 13, and we request that these individuals not provide personal information through the Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under CONTACTING US.
D. Access to and Choices About My Personal Information
You may modify your personal information that you have submitted by logging into your account on Our Site and updating your profile information. In other cases, you can contact us at firstname.lastname@example.org. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Site for a period of time.
We may communicate with you via email if you purchase products or services from us. For example, we may email you to confirm and otherwise facilitate your purchase, send you information about changes to our products and/or services, and, if applicable, send you notices and other disclosures as required by law. Generally, you cannot opt-out of
these informational communications.
We may also send you marketing or promotional emails. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving these marketing or promotional emails please note that, as described above, we may still send you emails in certain circumstances.
E. Product Review Boards, Chat Rooms, Forums, and Other Posting Areas
F. Promotions with Third Parties
G. Third Party Web Sites
This Policy applies solely to information collected on this Site. The Site may contain links to other websites, and any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the privacy practices of these other websites.
H. International Transfers
We are a global company, with offices located in many countries. As such, your personal information may be stored in a country other than the United States in servers or in locations where we have a global office or where a global service provider is situated. For example, Our Site services are located in Poland and Amsterdam, whose data privacy and security rules may be different from those found in your own country.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking by disabling cookies or opting-out of targeted advertising as noted below.
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
· Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
· Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
(2) Local Storage Objects
We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of personal information stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
(3) Clear GIFs, Pixel Tags and Other Technologies
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our e-mails are viewed, and track whether our emails are forwarded.
(4) Third Party Analytics
Cross-Device Use. We and our third party service providers, including Google, may use the information that we collect about you (whether directly from our Site, through your device(s), or from a third party) to help us and our third party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We, and our third party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third-Party Ad Networks section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.
(5) Third-Party Ad Networks
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
K. Do Not Sell
This Site contains a “Do Not Sell My Personal Information” page here. We do not sell any of your personal information for any purpose to any third parties. Any unintentional or incidental information exchanges with our third-party partners are not intended to be for consideration.
L. Your California Privacy Rights (as provided by California Civil Code Section 1798.83)
If you are a resident of California, you may have the right to request and receive certain information about a company’s disclosure of your personal information to third parties for their own direct marketing use, and your choices with respect to such disclosures. Because we do not share your personal information with third parties for their own direct marketing use unless you elected that we do so, we are exempt from this requirement. For any further information about how we comply with this requirement, please contact us as outlined below.
No method of data transmissions over the Internet can be guaranteed to be 100% secure, so, we cannot ensure the security of any information you transmit to us. We do incorporate commercially reasonable technical and administrative means intended to provide security on our systems from corruption, loss, unauthorized access, or misuse. You should take steps to protect against unauthorized access to your password by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. If you feel that the security of any information or any account that you have with us may have been compromised, please contact us immediately as outlined below.
N. EU-U.S. Privacy Shield/Swiss-US Privacy Shield
We comply with the requirements of 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 (the "Privacy Shield Principles"). We adhere to the Privacy Shield Principles 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), the United Kingdom and Switzerland to the United States. In doing so, we have certified that, in respect of all personal information we receive from the EEA, the United Kingdom and Switzerland, we 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 learn more about the Privacy Shield program, and to find details of our certification, please visit www.privacyshield.gov/list. The following entities are covered by our Privacy Shield certification: Reckitt Benckiser LLC and RB Manufacturing LLC.
With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including as required to meet national security or law enforcement requirements. We do not offer an opportunity to opt out from this category of disclosure.
We will provide an individual opt-out choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. In the event that we ever collect, use, or share sensitive data, we will provide appropriate opt-in choice.
In compliance with the Privacy Shield Principles, we are committed to resolve complaints about our collection or use of your personal information. If you believe that we are processing your personal information within the scope of its Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance in the following ways:
(1) You should first direct any questions or complaints to email@example.com or you can write to us at the following mailing address:
Reckitt Benckiser LLC
399 Interpace Parkway
Parsippany, NJ 07054-0225
Attn: Consumer Relations
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal information within 45 days of receiving your complaint.
(2) If you are not satisfied with our response, or for complaints that cannot be resolved with us directly, we have committed to refer unresolved privacy complaints under the Privacy Shield via the American Arbitration Association – International Centre for Dispute Resolution ("AAA"), an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgement of your complaint, or if you believe that your complaint has not been satisfactorily addressed by us, please visit the website http://go.adr.org/privacyshield.html for more information on how to file a complaint directly with the AAA.
(3) Further, your complaint can be made or referred to the US Department of Commerce or the Federal Trade Commission for further investigation.
(4) 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 see http://privacyshield.gov/article/My-Rights-under-Privacy-Shield.
Our commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
O. Contacting Us
If you have any questions about this Policy or our privacy practices, please contact us at firstname.lastname@example.org or 800-228-4722 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. Rights to Your Data and Deletion of Your Data
As a consumer, in certain states and under certain instances, you are permitted to discover what information We have collected from you and to request deletion of that information from us. Please see our Data Subject Access Request page here.
Q. Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.