Privacy Policy

PZ Cussons (International) Limited respects your privacy and is committed to protecting your personal data.

This policy (“Privacy Policy”) explains how we, PZ Cussons, and companies within our PZ Cussons Group (as defined below) process your personal information (personal data, for short) and, amongst other things, the lawful bases upon which we rely on to do so (if and where relevant), as well as any exceptions which allow us to process your personal information, without relying on a lawful basis.

PZ Cussons (International) Limited is the data controller and decides how your personal data is processed (“PZ Cussons”, “we”, “us” or “our”, for short, in this Privacy Policy). “PZ Cussons Group” shall mean PZ Cussons and any subsidiaries and any ultimate holding company of PZ Cussons (together with any of its subsidiaries), as such terms are defined in Section 1159 (and any associated provisions) of the Companies Act 2006 from time to time.

Our Data Protection Office, (the “DPO”) is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy or if you would like to make a request to exercise your legal rights, please contact the DPO using the contact details set out below.

[email protected]

For other relevant policies, please see our Website’s Terms of Service and our Cookie Policy.

 

Purpose of this privacy policy

 

This Privacy Policy provides you with information about how PZ Cussons collects and processes your personal data. This Privacy Policy applies to you if you visit our website (www.pzcussons.com) (regardless of where you visit it from), if you enquire about our services, purchase our services, or otherwise interact with us. However, please note that if you we are processing your personal data because you are an employee our Employee Privacy Policy will apply.

 

 

Changes to our website

 

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. For example, if you are an employee then your personal data will also be processed in accordance with our Employee Privacy Notice. This Privacy Policy supplements other notices and privacy policies and is not intended to override them unless this is clear from the context.

 

 

Third party links

 

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

Children’s data

 

Our website is not intended for users under the age of 18, and we would ask that such users do not provide personal data to us via the website. Please contact the DPO on the contact details above if this raises any concerns.

 

Personal Data We Collect About You

 

Personal data is any information about an individual from which that person can be identified. It does not include information derived from personal data where the identity has been removed, such that the person can no longer be directly or indirectly identified from the information (anonymous data).

We may collect, use, store and transfer different types of your personal data which we have grouped together as follows:

  • Identity Data includes your first and last name, date of birth and gender.
  • Contact Data includes your email address (both personal and or business), phone number and address.
  • Customer Service Data: includes details of any enquiries you have made to us, services you have purchased from us, and feedback or survey responses you have provided to us.
  • Profile Data: includes your username and password, your experiences of using our products.
  • Log Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the type of device you are using, its operating system, unique device identifiers, your device settings and geo-location data, the pages you visit, the time you spend on each page and the date and time of your visit.
  • Marketing and Communications Data includes your interests (both personal and professional), your preferences in receiving marketing from us and your communication preferences.

We may also collect, use and share aggregated anonymous data such as [statistical or demographic data for any purpose. For example, we may aggregate your Log Data to calculate the percentage of website visitors accessing a specific website feature. However, if we combine or connect aggregated anonymous data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

If you don’t provide us with your personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you don’t provide us with that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

 

How we collect your personal data

 

We use different methods to collect data from and about you, including through:

  • Direct interactions: you may give us your personal data by filling in forms, signing up for our newsletter or competitions or corresponding with us by post, phone, email or otherwise. This includes personal data you provide us when you:
    • make an enquiry about our products/services;
    • subscribe to our newsletter;
    • enter into a competition or promotion;
    • purchase our goods;
    • purchase our services;
    • use our platform or applications;
    • provide us with feedback;
    • fill out a survey or submission; or
    • contact us via email or telephone.

 

  • Automated technologies or interactions: as you interact with our website, services, we will automatically collect your Profile Data and Log Data. We collect this data by using cookies, server logs and other similar technologies. We may also receive Log Data about you if you visit other websites employing our cookies. Please see our cookie policy further details.

 

  • Third parties: we will receive your personal data from various third parties as set our below and outlined within our Cookie Policy
    • details of your visits such as how long you have visited the site, pages you have viewed and resources accessed, how long you have visited particular areas of the site, how you have used any interactive features; including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access; and/or
    • information about your device or computer, including, where available, your location, your IP address, operating system and browser type.

 

How we use your personal data

 

We collect and use your personal data for different purposes depending on how you interact with us and the services that we supply to you or your business. Data protection law requires us to have a legal basis to process your personal data for each particular purpose. We will only use your personal data when we have a legal basis for doing so. Most commonly, we will rely on one of the following legal bases:

  • Consent: You have given us consent to the processing of your personal data for one or more specific purposes.
  • Contract: Where it is necessary to perform the contract, we are about to enter into or have entered into with you.
  • Legal Obligation: Processing is necessary for compliance with a legal obligation to which PZ Cussons is subject to under UK law.
  • Vital Interests: Processing is necessary to protect the vital interests of your or of another natural person.
  • Public Task: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in PZ Cussons.
  • Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by PZ Cussons or by a third party, except where such interests are overriding by the interests of fundamental rights and freedoms of you which require the protection of personal data.

 

Purposes for which we will use your personal data

 

We have set out below, in a table format, a description of purposes for which we may use your personal data, which of the legal bases we rely on to do so, and the types of personal data processed for each purpose. We have also identified what our legitimate interests are where appropriate.

In some cases, we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your personal data. Please contact us if you would like more detailed information about how we process your personal data.

We may also inform you of additional purposes for processing your personal data when that information is collected from you.

Purpose/ Activity Legal basis for processing (including details of legitimate interests) Type of personal data processed Parties we might share your personal data with

Providing Products and Services

Using your information to provide you with further information about PZ Cussons, our products and services and to communicate with you about these topics.

 Legitimate Interest Your product selection, your name, your contact details and any further relevant information required. PZ Cussons (International) Limited, together with other companies in the PZ Cussons Group.

Site Registration and Activity

To enable us to register you on our site and if you have activated your cookies, to provide you with a better experience on our site, such as pre-populating fields with your preferences (which might include your location).

 Legitimate Interest Activated Cookies, IP Location PZ Cussons (International) Limited together with other companies in the PZ Cussons Group.

Respond and process enquiries, suggestions and complaints

Adequately responding to any enquiry, suggestion or complaint or to comply with contractual or regulatory requirements.

 Legitimate Interest Any information provided to us via an enquiry, suggestion or complaint or any information provided through the contact us page. PZ Cussons (International) Limited together with other companies in the PZ Cussons Group. or any regulatory bodies.

Legal and regulatory purposes

We may use personal data that we have gathered from you or third parties (such as law enforcement) to comply with our legal obligations or for other legal reasons- for example this could be fraudulent activity.

 Legal Obligation Your name, date of birth, contact details, address and any further relevant information as is requested by the relevant legal body. PZ Cussons (International) Limited together with other companies in the PZ Cussons Group. and any legal organisation or body as required to do so.

 

We will only use your personal data where that is permitted by laws that protect your privacy rights. We will only use your personal data where we:

  • have your consent (if consent is required);
  • need to use the information for compliance with legal obligations;
  • need to use the information to perform a contract with you; or
  • it is fair to use the personal information either in our interests or someone else’s interests, where there is no disadvantage to you (what is known as a ‘legitimate interest’) this can include where it is in our interests to market additional products or services to you.

 

Sharing your personal information

 

We may share your personal information with the following categories of third parties:

  • our service providers where necessary to make the products and services available to you such as suppliers of IT Services;
  • to promote our products and services to you, such as marketing agencies and social media platforms who may send targeted and automated messages to you;
  • where we or our group substantially all of its assets are acquired by a third party, personal information held by us will be one of the transferred assets and your personal information may be transferred to a prospective purchase and/or will be transferred to the new owner, to be used for the purposes set out in this Privacy Policy; and
  • where necessary to protect the rights, property, or safety of our group of companies, our customers, or others we may share personal information with law enforcement agencies.

 

Cookies

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

 

Change of purpose

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is lawful and compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we intend to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that, in limited circumstances, we may process your personal data without your knowledge or consent where this is required or permitted by applicable law.

 

International data transfers

 

We store and process your personal data in the UK and outside of the UK and/or EEA. In addition, some of our external third parties are based outside of the UK and/or EEA so their processing of your personal data will involve a transfer of that data outside the UK and/or EEA.

Whenever we transfer your personal data outside of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK and/or EEA; and/or
  • using approved international data transfer agreement (IDTA), standard contractual clauses and/or applicable UK Addendum/a which give personal data the same protection it has in the UK and/or EEA; and/or
  • implementing appropriate contractual and technical safeguards as and where necessary (together with any applicable transfer risk or impact assessments), and/or
  • transferring when one or more of the conditions set out in Article 49 UK GDPR are met (to the extent applicable).

 

Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include limiting access to your personal data to our employees, contractors, agents and other third parties who have a business need to access it. We ensure that all relevant training and resources are provided to our employees, contractors, agents and other third parties with regards to data security.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

How long we keep your personal data for

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. These purposes may include satisfying legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal data if we reasonably believe it may be needed in relation to a complaint or in order for us to exercise or defend a legal claim.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as any other relevant legal, regulatory, tax, accounting or other requirements.

If you want to know more about how long, we keep your data please contact us at [email protected]. In some circumstances you can ask us to delete your data: see your legal rights section below for more details.

 

Your legal rights

 

Under certain circumstances, you have rights under data protection law in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful, but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or, where technically feasible, another data controller where you have provided it in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

 

No fee usually required

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

What we may need from you

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

 

We try to respond to all legitimate requests within one month. It could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

What we ask of you:

 

  • Keeping your information accurate and up to date: please inform us if there is a change in your contact details or any other information that you have provided to us so that we can ensure our records are kept accurate and up to date.

 

  • Third party personal data: If you provide us with personal data about another person, please make sure that you have informed them of our identity, the purposes for which their personal data will be processed; and obtained their permission and/or complied with any other data protection requirements. If you are unsure whether their personal data can be shared with us, please contact us before providing us the data.

 

Automated decision making and use of Artificial Intelligence or “AI” (or emerging technologies)

 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We will only use automated decision-making in the following circumstances:

  • Where we have notified you of the decision and given you the opportunity to request a reconsideration of that decision.
  • Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
  • In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

Similarly, where we use, implement or deploy AI or emerging technologies, we will customarily carry out a data privacy impact assessment or AI risk assessment to identify and mitigate any risk(s) associated with the use of such technologies, such as minimise or removing bias and ensuring fair processing and, wherever practicable, being transparent as to where and when such technologies are used and seeking to design processes that minimise or remove such risks where third parties provide such applications which access, use or processing your personal data. For further details of how we use AI, please see our AI Policy (if applicable).

 

Contact details

 

Data controller PZ Cussons (International) Limited, company number 00706511 whose address is Manchester Business Park, 3500 Aviator Way, Manchester, M22 5TG.

Email address: [email protected]

This Privacy Policy is overseen by the DPO.  If you have any queries, complaints or requests relating to any entities within PZ Cussons, please contact the DPO at [email protected].

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

 

Updates to the Privacy Policy

 

We may revise, alter and reissue this Privacy Policy at any time. If we make changes to our Privacy Policy, we will update this page. Customarily any changes will come into effect 30 days after the date of the notice informing you of such changes or, if earlier, the next time you access the website and/or provide us with any personal data (or update your personal details) after the date of such notice.  Please therefore check this policy and any notices surrounding any changes from time to time and contact us if you have any queries [email protected]

If we make material changes to our Privacy Policy, we may also provide you with additional notification of those changes via email therefore we would also ask that you notify us if your contact details change.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

 

Approval and Coming into Force

 

This policy was approved by the DPO and comes into effect on 24/03/2006.

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