Our Privacy Policy

We know that you care how your personal data is used and we recognize the importance of protecting your privacy.

This Privacy Statement explains how Nutricia Export B.V. (“Nutricia”) collects and manages your personal data. It contains information on what data we collect, how we use it, why we need it and how it can benefit you.

Contact us here if you have any queries and comments, or if you want to make a request regarding any of your data subject rights.

At Nutricia, we are committed to protecting your right to privacy. We aim to protect any personal data we hold, to manage your personal data in a responsible way and to be transparent in our practices. Your trust is important to us. We have therefore committed ourselves to the following basic principles:

• ·You have no obligation to provide any personal data requested by us. However, if you choose not to, we may not be able to provide you with some services or products;
• We only collect and process your data for the purposes set out in this Privacy Statement or for specific purposes that we share with you and/or that you have consented to;
• ·We aim to collect, process and use as little personal data as possible;
• When we do collect your personal data, we aim to keep it as accurate and up to date as possible.
• If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
• Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement.

The personal data we collect varies depending upon the purpose of the collection and the product or service we are providing you.

Generally, we may collect the following types of personal data from you directly:

1. Personal contact data, such as your name, email address, physical address and telephone numbers;
2. Account login details, such as your user ID, e-mail username and password. This is necessary to create a personal user account on one of our online communities;
3. Communications with us, which may include details of our conversations via chat, care lines and/or customer service lines;
4. Demographic information, such as your age and gender and lifestyle preferences. Lifestyle preferences may include your preference for some of the products we offer, and your interests related to those products;
5. Browser history, such as pages accessed, date of access, location when accessed, and IP address;
6. Payment information for purchases made on one of our online shops. Payment information generally relates to your billing name, billing address and payment data, such as your credit card details or bank account number.
7. Information related to your health;
8. Information about people other than you, such as personal data about your family members, when you provide such information directly to us;
9. Social media profiles;
10. If ever you apply for employment with us, we will collect additional personal data, such as your employment history, educational history and employment references.

We may also collect personal data about you indirectly when:

1. you share content on social media pages, websites or applications related to our products or in response to our promotional material on social media; or
2. we read or collect personal data about you by reading information collected by other websites (for instance, we may place an ad on a third party website, and when you click on that ad, we may receive information about you and other website visitors in order to measure the reach and success of that ad).

We collect your personal data so we can provide you with the best online experience and to provide you with a high quality of customer service. In particular we may collect, hold, use and disclose your personal data for the following purposes:

1. To process your payments, if you purchase our products, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;
2. To process and answer your inquiries or to contact you in order to answer your questions and/or requests;
3. To develop and improve our products, services, communication methods and the functionality of our websites;
4. To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
5. To manage our everyday business needs in connection with your participation in our contests, sweepstakes or promotional activities or request;
6. To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
7. For internal training and quality assurance purposes;
8. To understand and assess the interests, wants, and changing needs of customers, in order to improving our website, our current products and services, and/or developing new products and services;
9. To provide personalized products and communications as well as product recommendations to you a customers;

We may also need your personal data to comply with legal obligations or in the context of a contractual relationship that we have with you.

When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.  

Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time. 

Where we process your personal data, you are entitled to a number of rights and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights via our contact page .

The right to access your personal data and correction

You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us via our contact page .

The right to data portability

Your personal data is portable. This means it can be moved, copied or transmitted electronically. However, this right only applies where:

a) The processing is based on your consent;

b) The processing takes place for the performance of a contract;

c) The processing takes place by automated means;

If you wish to exercise your right to data portability, please contact us via our contact page.

The right to deletion of your personal data

You have right to request that we delete your data if:

1. your personal data is no longer necessary in relation to the purposes for which we collected it; or
2. you withdraw the consent that you had previously given us to process your personal data, and there is no other legal ground to process that personal data; or
3. you object to us processing your personal data for direct marketing purposes; or
4. you object to us processing your personal data for Nutricia’s legitimate interests (such as improving overall user experience on websites);
5. the personal data is not being processed lawfully; or
6. your personal data needs to be deleted to comply with the  law.

If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.

If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.

The right to restriction of processing

You have the right to restrict the processing of your personal data if

1. you do not believe the personal data we have about you is accurate; or
2. the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or
3. we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or
4. you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to restrict our processing of your personal data, please let us know we will take reasonable steps to respond to your request in accordance with legal requirements.

The right to object

You have the right to object to the processing of your personal data at any time. Please contact us via our contact page .

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint directly with supervisory authority about how we process personal data. 

We understand that the security of your personal data is important. We make our best efforts to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure. We have implemented a number of security measures to help protect your personal data. For example, we implement access controls, use firewalls and secure servers, and we encrypt personal data. 

When we share your personal data with affiliates and other organizations, we make sure we only do so with organizations that safeguard and protect your personal data and comply with applicable privacy laws in the same or similar way that we do.

Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement. We may, however, share your data when required by law and/or government authorities.  

Personal data may be processed outside the European Economic Area (EEA). When processed outside the EEA, Nutricia will make sure that this cross-border data processing is protected by adequate safeguards.

The safeguards that we use to protect cross-border data processing include:

1. aModel Contractual Clauses approved by European Commission. These standardized contractual clauses provide sufficient safeguards to meet the adequacy and security requirements of the European General Data Protection Regulation; or
2. Certifications which demonstrate that third parties outside of the EEA process personal data in a way that is consistent with the European General Data Protection Regulation. These certifications are approved either by the European Commission, a competent supervisory authority or a competent national accreditation body in terms of General Data Protection Regulation.

Your personal data may be freely transferred outside the national territory to countries located in the European Union. Should your personal data be transferred to countries outside the EU this shall occur exclusively in compliance with the appropriate and adequate guarantees for the purpose of the extended transfer in accordance with the applicable legislation and in particular article 27 of the Data Protection Act and articles 45 and 46 of the GDPR.

You will have the right to obtain a copy of the data held abroad and to obtain information about the place where such data is stored by expressly requesting us for this information through the contact information as presented below.

The following provisions have become effective as of 25 May 2018, when the GDPR has become enforceable.

1. Data Protection Officer: the appointed Data Protection Officer pursuant to article 37 of the GDPR can be contacted via the means provided at the end of this Notice.
2. Data retention period: We. will process your personal data for the period necessary to satisfy the purposes for which they were collected. In any case, the following retention periods apply to the processing of personal data for the following purposes:
   • the data collected for Contractual Purposes are kept for the entire duration of the period during which the requested service is provided to you and for 10 years following the expiration of this period for defence purposes and / or to exercise our rights in court and/or out of court in case of disputes with you.
   • the data collected for Legitimate Interest Purposes are kept for a period of 10 years from the time of collection.
   • Once the above terms have expired, your personal data may be deleted, anonymized and / or aggregated.
     
3. Additional rights: You can at any time
   • request the restriction of the processing of your personal data where one of the following applies:
     • you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
     • the processing is unlawful, and you oppose to the erasure of the personal data and requests the restriction of their use instead;
   • oppose at any time to the processing of your personal data:
   • request cancellation of personal data concerning you without undue delay;
   • obtain the portability of personal data concerning you;
   • lodge complaints with the appropriate Data Protection Supervisory Authority.

For some services and products we may process your personal data using automated means. Essentially this means that decisions are taken automatically without human intervention (example through the our ‘contact us’ page)

We may also process your personal data for profiling purposes to predict your behavior on our website or products that may be of interest to you (example through cookies).

If we intend to make use of such methods, we will of course inform you and we will give you an opportunity to object to these processes in advance. You are also free to contact us for further information on such processing.

We may also collect personal data about you through the use of cookies and other technologies. This may occur when you visit our sites or third-party sites, view our online promotions, or use our/third-party mobile applications and may include the following information:

1. Information about your device browser and operating system;
2. The IP address of the device you are using;
3. Web pages of ours that you view;
4. Links that you click while interactive with our services.

Please see our cookie statement for more information on this.

We process personal data as defined in the GDPR which was brought into force from May 25^th, 2018. We therefore consider that we have a legal duty to respect and protect any personal information we collect from you, and we will abide by such duty. We take all safeguards necessary to prevent unauthorized access and we do not pass on your details collected from you as a visitor, to any third party unless you give us your consent to do so.

This provides amongst other things that the data we hold about you should be processed lawfully and fairly. It should be accurate, relevant and not excessive. The information should be kept up to date and not retained for longer than is necessary.

To make sure that you can control your personal information we enable you to:

• Ask to view the personal information we hold about you;
• Request that any personal information that is inaccurate, irrelevant or out-of-date be amended or deleted;
• Have your personal information deleted, if such deletion is permissible by law and/or will not prejudice our position at law.

If you have any questions, comments or complaints regarding this Privacy Statement or the processing of your personal data, please contact us via our contact page.