Effective Date: 24 may 2018
UHU GmbH & Co. KG, Herrmannstraße 7, 77815 Bühl/Baden, Germany (“Company” or “we”), acting in the role of autonomous data controller and affiliate of the group of undertakings known as Bolton Group (the "Group"), wants to inform you about how we collect, use and disclose personal data from and about you, through this website www.uhu.com ("Website") and its connected services ("Services"), in compliance with all applicable data protection laws and regulations and with particular reference to: (i) Regulation (EU) no. 679 of 27th April 2016 (the so-called General Data Protection Code or "GDPR"), effective from May 25th, 2018; and (ii) any other act, order, regulation or provision of the competent national and European data protection authorities - hereinafter jointly the "Applicable Data Protection Legislation".
Please note that the Services may include, among other things, the possibility to participate to prize winning competitions, lotteries, contests and or other initiatives organized by the Company on a case by case basis, also in cooperation with the Group.
2. What type of personal data do we collect about you?
The company collects (1) data that you have volountarily shared with the company, (2) activity data collected when you access and interact with the website or the service and (3) additional information. More in particular, the company collects the following data from and about you:
- Registration data: collected through our registration form.
- Data that you have volountarily shared with the company: we might collect your personal data (such as name surname, email, address, phone number, etc.) if you submit a request through the contact form made available to you via the website, if you register an account on the website or if you are willing to benefit from the services we provide;
- Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information and commercially available sources.
When the information collected from or about you does not identify you as a specific person (e.g., raw, aggregated or anonimyed data), directly or indirectly, we may use that information for any purpose or share it with third parties, to the extent permitted by the Applicable Data Protection Legislation.
We do not collect
- Special categories of personal data: we ask that you do not send us, and you do not disclose, any information included in a special category of personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Website, the Services or otherwise.
3. Why do we collect your personal data?
We process the personal data we collect from and about you to:
a) allow you to use the website and the services;
b) measure and improve our services and the relevant features;
c) improve your experience with the website and the services;
d) provide you with customer support and to respond to inquiries;
e) comply with legal obligations (also including the provision of the services); or respond to requests from public and government authorities;
g) upon your optional consent, sending you customized marketing and promotional communications in line with your preferences and personal choices [JOINT CONSENT FOR MARKETING AND PROFILING];
h) upon your optional consent, share your data with our trusted business partners including other companies of the group, for allowing them to send you commercial messages.
When the data collected from or about you does not identify you personally, we may use that information for additional purposes or share it with third parties.
4. On what legal basis do we process your personal data?
The processing of your personal data for the purposes of:
5. How long do we retain your personal data?
The company will process the personal data for as long as is necessary to achieve the intended purposes pursuant to section 3 above. In any case, the following retention periods shall apply:
a) the data collected for the purposes of Section 3, lett. a), to d) will be retained for a period strictly necessary for allowing you the use of the website or the services;
b) the data collected for the purposes of Section 3, lett. e), will be retained for ten (10) years in order to respond to data subjects' requests and to comply with applicable laws and regulations, also with regards to the services;
c) the data collected for the purposes of Section 3, lett. f) will be retained for the period strictly necessary in order to pursue the company's legitimate interests;
d) the data collected for the purposes of section 3, lett. g) will be retained for the period strictly necessary in order to achieve the purpose for wich they were originally collected and, in any case, no longer than 2 years.
6. How do we process your personal data?
With regard to the above mentioned purposes, the data is processed through both electronic and manual means, and is protected through adequate security measures. With this regards, although the company uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification, it cannot guarantee that all possible cyber-risks can be excluded.
7. Who has access to your personal data?
a) Other companies of the Group, as the case may be;
b) Third parties service providers entrusted with processing activities and duly appointed as processors or sub-processors when required by applicable laws (e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the services - and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers - companies resulting from possible mergers, demergers, or other transformations); and
c) Competent national authorities in order to comply with applicable laws;
d) Trusted third parties business partners, upon your explicit consent. The categories to which such business partners belongs are: (i) consumer goods; (ii) personal care; (iii) beauty care; (iv) home care; (v) glues and sealants; etc.
8. Is your personal data transferred abroad?
We will not transfer the personal data in countries situated outside of the European Economic Area.
9. Minors under the age of 18
The website does not address subjects under the age of 18, nor is the company knowingly collecting personal data from people under the age of 18.
10. What are your rights with regard to your personal data?
The User may, at any time and at no charge have and/or exercise the following rights:
a) the right to be informed on the purposes and methods of the processing;
b) the right of access;
c) the right to obtain a copy of the data held overseas and obtain information concerning the place in which such data are kept;
d) the right to ask for updating, rectification or integration of the data;
e) the right to request the cancellation, anonymization or blocking of the data;
f) the right to limit the processing;
g) the right to object to the processing, wholly or partly, also where it is carried out through automated individual decision-making, including profiling;
h) the right to revoke the consent to the processing of the data freely and at any time.
i) the right to contact the data protection officer, as the case may be;
j) the right to lodge a complaint in front of the competent national data protection or judicial authority.
In addition to the rights listed above, from 25 May 2018 you may also exercise the following rights, as a result of the full applicability of Regulation (EU) no. 679 of April 27th, 2016:
a) the right to data portability (i.e., to receive an electronic copy of your personal data, if you would like to port your personal data to yourself or a different provider);
b) the right to limitation of the processing.
In case of any doubts, comments or complaints from the User on the personal data collection or methods of use, please contact us at privacy-UHU@boltonadhesives.com.
11. Amendments and updates