Dear visitor or user, welcome – back – to our website!
Who we are and how to reach out to us?
Note that in terms of privacy, we are considered as data controllers or business. This means that we are the ones that decide the how and the why of data handling. We determine what data will be processed, how the processing will take place, and the purpose for which it is processed.
When we talk about our trusted partners, they will be most frequently considered as data processors or service providers. They are a separate entity that processes the data on behalf of the controllers. They must obey any rules put forth by us, and handle the data as specified by us.
What data do we handle?
Depending on your interactions with us, we are going to collect, use, store or process your data that we can categorize as follows:
Username, password, or any other data allowing you to access your account.
Simple data to be able to communicate with you such as name, surname, email address, postal address, telephone numbers and similar.
Technical information collected when browsing the website including IP address, cookies, analytics and statistical data.
This data helps us, for example, to detect the language of your browser and therefore display the content in the correct language for you.
Your company related data such as company name, title, professional email or telephone numbers.
Data you exchange with us as a candidate for a job position including CV, photo, references, referrals, qualifications, education, applicable licenses or certifications, prior job history.
Information needed to allow you to shop on our webstores such as shipping address, payment information and similar.
Data you can voluntarily share with us to give more details about your age range, location, gender, address, website, job title, birthdate, product usage related information.
Your exchanges with us:
Data you send us when requesting information via forms or by email.
What about child data?
Our websites are not intended for use by children under the age of 13. Edgewell does not market any of its products online for children under the age of 13, nor do we design our online applications, advertisements, and/or other features to attract an audience of children under the age of 13.
Although certain pages within our websites may reference “kids,” “children,” or “students,” we strictly intend for such portions of the websites to be used only by adults (such as parents and teachers) or children of the age 13 or older. Edgewell does not knowingly register or otherwise collect data from any child under the age of 13.
Is it mandatory to share your data?
It is to be noted that the provision of certain data may be mandatory or optional, depending on the Services you wish to receive. Mandatory data will be marked as such when we require it. If you refuse to provide mandatory data, we may not be able to process your request.
If you would like to have the full list of data Edgewell has about you, please use this form or send us an email.
How do we use and share your data?
There are various ways to interact with us. Depending on the selected interaction, we need to collect, store and otherwise use your data for different purposes and based on various legal basis. The legal basis is simply the justification allowing us to handle your data.
Every time we collect your data, you will be informed and explained why by short text explanation and by pointing to this Privacy Notice. We can provide further details in our email communications.
In the following sections, you will see the usual interactions you can benefit from when visiting and using our websites. Not all our websites offer the listed Services and therefore we will only use and/or store your data if you select to use one or various Services.
You will also see each Service is subject to a dedicated terms and conditions that we will ask you to read and accept. Sometimes, we will ask you to confirm your age or that you are above a certain age. This is necessary to ensure we have the right to offer you such Services.
Browsing our website
When browsing our websites, you can do so without sharing any data. Nevertheless, we intend to have some data to be able to improve our Services to you or to customize your experience. This is, for instance, the case when detecting the language of your web browser to display the texts in the correct language. Such data is often kept in aggregated way – we cannot identify you behind the screen.
Some of our websites permit you to use, after your consent, a third-party social networking platforms. This includes use of social media plug-ins. When you use these social networking platforms and plugins, your account details for the Services and other information available about you or collected from you on these Services may be shared with us.
We may ask your permission to repost your social media quotes on our websites. If you agree, you grant us the right to use your posts on our websites for promotional purposes.
To learn more about cookies and social media plugins, the third parties we are potentially share your data with and how long do we keep your data, refer to our Cookie Notice.
If you wish to update your Cookies choices, you can simply click on the “Cookies preferences” link in our footer or in the Cookie notice.
Newsletters and email communications
If you choose to sign up for our newsletter or email communications, you must submit certain basic contact details during the registration process.
As we are using your consent to send you the communications, you can always opt out from them by clicking on the link in the received email or contacting us via this form or by email. Please give us a reasonable amount of time to process your unsubscribe request.
We may need to share your data with our trusted newsletter and email automation partners and we and our partners will only keep your data until you opt-out from our communications.
If you choose to create an account on our websites, you must complete the registration process by providing basic contact details. You may also be asked to choose account details. Please keep your username and password secure.
The processing of your data, when it comes to account creation, is based on your consent. You can always ask us to deactivate and delete your account by contacting us via this form or by email. Please give us a reasonable amount of time to process your request.
We will need to share your data with our partners helping us operate our websites such as our hosting or infrastructure providers. If possible, due to our legal obligations around data retention, both us and our partners will keep your data until you request that we delete your account.
Surveys and polls
While visiting certain portions of our websites, you may be given the opportunity to provide feedback regarding various Edgewell products. You may be given opportunities to rate our products and to publicly ask and answer questions pertaining to Edgewell products. In order to fully participate in these portions of our websites, you will be asked to create an account or provide contact details and create username which will be publicly linked to your product ratings, questions, answers and other comments.
You will be required to provide consent and agree to a set of terms and conditions which require, among other things, you to verify that you are over the age of 13. You may also be prompted to submit additional voluntary contributions. This information may be linked online to your chosen username. Edgewell stores this additional information, if provided, and may use it later to help us better understand and respond to the collective feedback we receive.
Occasionally, we may invite you to participate in a survey or poll such as providing feedback on our website content, services, or products. Your responses will be anonymous unless you choose to provide your contact details so that we can provide you with additional information regarding the survey or poll.
For any information that we collect through our surveys and polls, Edgewell becomes the owner of that information.
To organize surveys and polls, we will require the assistance of several partners helping us to collect and otherwise display or use the information. We will keep your data for the period indicated when collected and when the time comes, anonymize your data to permit us to continue using the responses without linking them to you or your username.
Some of our websites allow you to purchase our products online. To be able to process your order, you will need to complete your profile with shopping details. Once you agree to a set of terms and conditions, our contract is concluded and becomes the legal basis of this specific processing.
We will share your data with our trusted partners to assist us with contractual execution such as the invoice creation or delivery of products. We will need to keep your shopping details for specific retention periods to comply with our legal obligations when it comes to accounting or tax reporting.
Communicating with us
If you choose to contact us via our contact forms or by email, you must submit certain basic contact details to allow us to respond to your query. You will also provide us with your consent to use your data.
We will share your communications with our customer service and similar partners to be able to answer your query as soon as possible.
We will keep your data only during the period necessary to answer your questions or, when legal or administrative implications are present, for the necessary retention period based on our legal obligation or legitimate interest.
If you apply for a job with Edgewell through our websites, the data collected will include your professional history and any other information that you choose to include about yourself.
If you apply to become an approved supplier, the information we collect will include relevant professional data. We may also request additional information from your company, including an on-site audit or additional checking to ensure that our prospective partnership with you will be consistent with Edgewell’s business, legal and compliance expectations for our partners. If you become an approved supplier, we will also require other information from you that is relevant to our ongoing business relationship based on contract.
Pre-litigation and litigation management
We might need to hold your data to manage pre-litigation and litigation. This can be of our legitimate interest when investigating, for instance, breach or misuse of our websites.
We will only share your data with trusted partners helping us to manage such situations and we will keep it for limited periods of time according to the law.
Compliance with legal and regulatory obligations
We might need to hold your data to comply with our own legal obligations. This is for instance the case with the invoices related to your purchases.
We will only share your data with trusted partners helping us to manage such situations and we will keep it for limited periods of time according to the law.
Special case of promotions
From time to time, Edgewell may run promotions offering special deals, coupons, discounts, chances to win contests, and other prizes. These promotions may involve third-parties.
In order to participate in these promotions, Edgewell may request certain basic information about you, such as your name, email address, physical address, and date of birth. This and other information provided to participate in the promotions may be processed by Edgewell in order to help us better understand how we can design and market our products for you and others. This information may also be shared with any relevant third-party promotional partners involved in the specific promotion for which you choose to sign-up. In addition, certain third-party promotional partners may use your information to contact you in order to provide you with more information about their company and with further opportunities to make additional purchases. Please remember that Edgewell is not responsible for the information practices of third parties to whom you choose to disclose information.
Who can access your data?
Depending on the selected interaction and used Services, Edgewell may share your information within the Edgewell group of companies as well as with trusted third-party service providers that assist us with our websites, contests and sweepstakes, such as providing the products or services that you requested or for the purposes of improving our marketing or administration. This includes companies that provide analytics to us about the use of our websites, so that we can evaluate the use of our websites and continue to improve our websites’ content.
Those third-party providers shall only be granted access to the data they need to perform their designated functions and will be subject to confidentiality and data protection obligations regarding such information and will not be authorized to use your personal data for their own business purposes.
Except as explained in the section “Special case of Promotions,” Edgewell does not share or sell any personal information that you provide to us through our websites for any separate use by any third party for its own purposes.
However, from time to time, we may provide aggregated (statistical) information about our customers, sales, online traffic patterns and related information to third parties who help us improve our business and services, but these statistics do not include any personally identifying information.
In the event that we sell, assign or transfer all or part of the Edgewell business (including in the event of a reorganization, dissolution or liquidation), we may transfer your personal information to a third party.
How long do we keep your data?
Your data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.
In the absence of applicable exceptions:
- the data collected via the forms on the websites (contact form/information request, etc.) will be kept until the complete processing of your request;
- the data collected for your subscription to the newsletters and email communications will be kept until you unsubscribe;
- the data collected via the recruitment form will be kept for a period of two (2) years after our last contact with you, except if the local legislation requires different retention period or in the event of request for deletion of your file;
- your traffic data will be kept up to thirteen (13) months from the connection date.
In addition to this and unless local legislation requires different retention periods, we will keep data during:
- five (5) years for evidence purposes relating to legal claims;
- ten (10) years from the end of the relevant fiscal year for personal data retained for accounting purposes as well as for commercial documents.
If you would like to have the full list of data Edgewell has about you and for how long it is retained, please use this form or send us an email.
Where is the data stored?
Our local websites are intended for residents of the local country. If you happen to live in another country yet use our websites initially for different residents, any data collected about you with respect to your use of our websites might be transferred to the pertinent country or geographical area. As such, please note that there may be different standards that apply to how your data may be used and protected than the standards in place in your country. Nevertheless, Edgewell has put in place safeguards to protect your data irrespective of the country from which it originates.
Refer to our Legal Mentions to know which is the hosting country of your data.
How do we safeguard your data?
Edgewell maintains physical, technical, and administrative safeguards that are designed to protect your personal information from loss, misuse, unauthorized alteration, theft, unauthorized access, and unauthorized disclosure.
We use modern encryption methods that only a limited number of personnel have access to the data.
We guarantee that our personnel and any other individual handling your data will respect our rules and procedures related to the processing of personal data, including the technical and organizational security measures put in place to protect your data. In this context, we review and update our practices regularly to enhance your privacy and ensure that its internal policies are followed.
All of our suppliers are bound by the same level of protection of your data as Edgewell.
What are your rights?
Under certain circumstances, you may have the following rights under data protection laws over your data:
Right of Access or to Know
In addition to this Privacy Notice, you can request the confirmation we are holding your data.
Right to be Informed or to Know
You can obtain clear, transparent and understandable information on how we process your data and on your rights, as well as a copy of your personal data.
Right to withdraw Consent
You can withdraw your consent, at any time, for the purposes for which your consent has been obtained.
Right to Opt-out or Unsubscribe or to Object
You can object to the processing of your data when the processing is based on our legitimate interest or if we are using personal data for direct marketing purposes. You will be informed that you have a right to object at the time of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information.
Right to Rectification or Correction
You can request the rectification or correction of your data to obtain the modification of your personal data if they are obsolete, inaccurate or incomplete. If we have disclosed your data to any third parties, we will take reasonable steps to inform those third parties of the request where possible.
You can also directly update your data in your account.
Right to Erasure/to be Forgotten
You can request the deletion of your data (or right to be forgotten). Before deleting your data, we will consider your request carefully in accordance with the requirements of any pertinent laws and will let you know if we are able to erase your data.
Right to Restriction or Limit of Processing
In certain specific circumstances you have the right to block the processing of your data. This right arises if you are disputing the accuracy of your data, if you have raised an objection to processing, if processing of data is unlawful and you oppose erasure and request restriction instead or if the data is no longer required by us but you require the personal data to be retained to establish, exercise or defend a legal claim.
In particular, you can as us to limit the processing of your sensitive personal information such as social security number, religious beliefs etc. to a use and disclosure for specific business purposes only.
Right to Data Portability or to Transfer
In certain specific circumstances, you can ask to receive your data in a structured, commonly used and machine-readable format and also can request their transmission to another controller where technically feasible. This right is subject to several conditions, the main being the processing is based on consent or on a contract.
Right to oppose to Automated Decision Making
You have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.
Right to request Do Not Sell or Share
You can request us to be informed if your data is sold or shared and require us not to proceed with such operations.
If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.
If needed, you can also exercise the specific rights your local legislation is giving you such as defining the guidelines regarding the use of your data in case of your death.
It is obvious that the names of the rights might vary depending on local legislation and definitions. The spirit remains the same.
Under certain circumstances, we may ask you for specific information to confirm your identity and ensure the exercise of your rights. This is another security measure to ensure that your data is not disclosed to an individual who does not have the right to receive it.
If you have any questions or wish to exercise your rights, you may fill in this form or directly contact us by sending an email to email@example.com.
As we continue to provide additional Services and as the privacy laws and regulations evolve, it may be necessary to revise or update this Policy. We encourage you to review this Policy from time to time, as you return to our websites, so that you are familiar with any changes. For significant changes, we will notify you by posting a prominent notice on our websites indicating at the bottom of the Policy when it was most recently updated.
If you use assistive technology and the format of this Privacy Notice interferes with your ability to access information, please contact us to enable us to respond in a manner most helpful to you, please indicate the preferred format in which to receive the material and your contact information.