Updated January 2022
2. Information Collection
4. Opt-out of PII Emails
5. Automatic Data Collection and Interest-Based Advertising
6. Public Information on the PDC Sites
7. California Privacy Rights
8. PII Transferred Outside Country of Residence
10. Changes to this policy
12. PII Retention
13. Contact Us
B. Supplemental Privacy Provisions for Persons in the European Union
If you are in the European Union, please also review PDC’s Supplemental Privacy Provisions for Persons in the European Union. These EU Supplemental Privacy Provisions provide additional information regarding PDC’s processing of personal data you submit or disclose to PDC while you are in the European Union.
2. Information Collection
We collect and store a variety of information from and about you when you visit and interact with the PDC Sites. Some information is personal and some is not. It is important that you understand what information we collect when you visit the PDC Sites from a computer or a mobile device and what we may do with that information.
- Personally Identifiable Information (PII)
Personally Identifiable Information (“PII”) includes but is not limited to your name, mailing address, e-mail address, postal address, telephone number, date of birth, image, user-generated content, posts and other content you submit to PDC Sites, any other personal information you voluntarily provide to us, or information that can be used to identify you when combined with other information. Providing PII to the PDC Sites is on a voluntary basis, however, if you opt not to provide the PDC Sites with certain PII, you may be unable to access all functions of the PDC Sites, including but not limited to, creating a user account (“Account”), participating in Sweepstakes, or receiving advertising or promotional offers. In addition, you may be asked to submit your PII when contacting us about questions, inquiries or concerns or to provide services or support.
- Information that is Non-PII
Information that is gathered when you visit the PDC Sites is not necessarily PII. Information that does not identify you personally, such as your IP address, operating system, browser type and language, date and time of your visit, ISP, referring URL, Site pages most frequently accessed, search terms entered, your geographic region, industry, the type of content you view, etc. is Non-Personally Identifiable Information (“Non-PII”). We use Non-PII to help administer the PDC Sites and we reserve the right to share, sell or trade aggregated Non-PII with third parties. As stated earlier, Non-PII does not identify you individually. When Non-PII and PII are combined we refer to this as PII and the combined information will be treated by PDC as PII hereunder as long as it is so combined.
3. Use and Sharing of PII
• Sharing with Third Parties: Your PII may be shared with third parties as stated herein, including third-party service providers, advertising technology companies, advertising networks, suppliers or contractors that provide services to us and you acknowledge that such third parties may not be governed by the same policies as the PDC Sites. Certain services available on the PDC Sites may be provided by third parties, including without limitation, affiliates, sub-contractors, authorized vendors, data processors, email marketing companies, customer support specialists, Web hosting companies and fulfillment companies, and PDC may provide your PII to such third parties in order to deliver the services to you, including to provide you targeted advertising based upon your interests. These third parties are not authorized to retain, share, store or use your PII for any purposes other than to provide the services for which they have been retained to provide. PDC may also enhance or merge your PII with data obtained from third parties, such as information provided by a co-sponsor of a particular promotion, which PDC may then use for marketing and advertising activities..
• Transfer of PII: PDC may transfer, sell, assign or otherwise dispose of or encumber PII to third parties in connection with the sale, merger, consolidation, change in control, transfer of all or some assets, bankruptcy, reorganization or liquidation of PDC. In such case, you would not be entitled to any compensation arising from any such transfer, sale, assignment, disposition or encumbrance of your PII. Finally, PDC may disclose PII when required to do so under applicable law, including but not limited to comply with a legal requirement, judicial proceeding court order or legal process served on us; to investigate a possible crime, such as fraud or identity theft; or when we believe it is appropriate to do so to protect the rights, property, or safety of our company or other persons..
4. Opt-out of PDC Emails
5. Automatic Data Collection and Interest-Based Advertising
As you navigate through and interact with the PDC Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• Details of your visits to our PDC Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the PDC Sites.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
For example, you may use the Network Advertising Initiative’s Opt-Out Tool and the Digital Advertising Alliance’s Opt-Out Tool for information on how you can opt out of behavioral tracking on the PDC Sites and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. We may also use Google Analytics and Google AdWords on the PDC Sites to collect Usage Information, to analyze how users use the PDC Sites and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
The technologies we use for this automatic data collection may include:
• Web Beacons. Pages of the PDC Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit PDC, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
By using our PDC Sites, you agree to us using these automatic data collection technologies, including placing cookies on your device and accessing them when you visit the PDC Sites in the future. If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies.
6. Public Information on the PDC Sites
Certain activities that you choose to participate in on the PDC Sites may be public. This includes, but is not limited to, linking your Account with other social media platforms, clicking through to other PDC Sites or to advertisements, participating in certain activities on the PDC Sites, or entering into Sweepstakes. A brief explanation of some forms of information that may be displayed publicly is found below:
• Public Forums: From time to time you may be able to participate in certain activities on the PDC Sites, such as chat rooms or bulletin boards, which will allow you the opportunity to communicate with PDC or other users of the PDC Sites. Unless otherwise noted, these activities may be generally accessible to all users of the PDC Sites and any information that you post or otherwise make available through these forums will be non-confidential and known to all other users. Accordingly, please exercise discretion when using these forums and when publishing any PII in these forums. You acknowledge and agree that PDC does not review, censor, or in any manner control the content of these forums and consequently PDC has no liability or responsibility whatsoever for information made available through these forums and that you will be liable to PDC for any liability that we incur as a result of any statement made by you in these forums. Your use of these forums is also subject to PDC’s Terms and Conditions..
• Social media: From time to time you may be able to create an Account and link your Account with third-party social networking sites, such as Facebook, Instagram, and Twitter or with other social media applications or plug-ins. By choosing to link your Account in these manners, you allow us to have access to PII and non-PII available in your social network or social media profile and your PII may be viewed or possibly used by other members of these PDC Sites. Be mindful when choosing to link your Account with other applications or plug-ins. Any Sweepstakes on third-party social networking sites, in addition to being subject to the specific rules and/or terms and conditions applicable to your participation in such feature(s) on the PDC Sites, will also be subject to the rules and/or terms and conditions applicable to your participation in such feature(s) on those third party sites.
• Advertisements: Our PDC Sites may feature advertisements served by third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) to our PDC Sites. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to help us deliver customized content and advertising to you when you visit PDC Sites or Third Party Sites. These third parties may also collect Non-PII such as your IP address and your viewing habits of the advertisement. PDC is not responsible for these cookies or any data collected through use of these cookies, web beacons, or pixels. The advertisement service providers are solely responsible for the information they collect and how they use that information. Depending on your location, there may be other solutions to help you control your online behavioral advertising preferences (such as whether certain third parties may collect and use your Non-PII for targeted advertising purposes). For example, you may use the Network Advertising Initiative’s Opt-Out Tool and the Digital Advertising Alliance’s Opt-Out Tool.
7. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
If applicable, request a copy of the information disclosure pursuant to Section 1798.83 of the California Civil Code by writing to us at: PDC BRANDS, 750 E. Main Street, Stamford, CT 06902, Attn: PDC Customer Service California Privacy Law. Please include your full name and address and PDC Sites Username, if applicable.
8. PII Transferred Outside Country of Residence
PDC has no intention to knowingly collect any PII from individuals under the age of 16 years. If PDC learns that a child under the age of 16 years has provided PII to the PDC Sites without verifiable parental consent, PDC will use commercially reasonable efforts to delete such information from its databases. If you believe your child, who is under 16, has submitted PII to the PDC Sites, please contact us via one of the methods described on our Contact Us page.
10. Changes to this policy
PDC takes the protection of your personal information seriously. We utilize reasonable and appropriate security measures to help protect the information under our control. However, no Internet data transmission can be guaranteed to be completely secure. All information provided to us is provided at your own risk. PDC may store your information, in whole or in part, on equipment or in facilities leased or licensed from other vendors or entities. We rely on the safety and security statements of such vendors with regard to their storage equipment and services. By using the PDC Sites, you agree that PDC is not responsible for any issues related to the electronic storage equipment and services of other vendors or entities, including, but not limited to, the release, loss or corruption of your data. You also agree that you will seek remedy from the vendors or entities for any such issue and not PDC.
12. PII Retention
We will only retain your PII so long as it is necessary for the purposes it was collected, for the products and services that you use, or to meet any and all legal requirements. Your personal information will be deleted when it is no longer needed for any of these purposes.
13. Contact Us
- see personal information that you have sent us in order to correct or update it, or delete your personal information from our files;
- if your child has sent us personal information and you would like to delete that personal information from our files;
- ask that we not send you mailings or otherwise contact you; or
you can contact us through our Contact Us page or by sending correspondence to:
- Corporate Inquiries: firstname.lastname@example.org
- Customer Service Emails: email@example.com
- Mailing address: PDC BRANDS, 750 E. Main Street, Floor 10, Stamford, CT 06902.
B. Supplemental Privacy Provisions for Persons in the European Union
These Supplemental Privacy Provisions for Persons in the European Union (EU Privacy Provisions) are provided pursuant to Regulation (EU) 2016/679 (“Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data”) (the GDPR), effective May 25, 2018.
These EU Privacy Provisions apply to you only if and to the extent PDC is Processing your Personal Data you submit or disclose to PDC while you are in the European Union (EU), where the Processing is related to PDC offering goods or services to you in the EU, or PDC is monitoring your behavior in the EU.
Capitalized terms used in this Notice have the meaning set out in Section (S) below.
(A) This Notice
|Summary – This Notice|
|This Notice explains how we Process Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.|
This Notice is issued by each of the Controller entities listed in Section (R) below (together, “PDC”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact. This includes visitors to our Sites, individuals who sign up to marketing or who participate in promotions or awards we operate, our customers and other users of our products or services, individuals who contact us or and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (S) below.
This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.
(B) Collection of Personal Data
|Summary – Collection of Personal Data|
|We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).|
Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:
- Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
- Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
- Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
- Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
- Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.
- Content and advertising information: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
- Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).>
(C) Creation of Personal Data
|Summary – Creation of Personal Data|
|We create Personal Data about you (e.g., records of your interactions with us).|
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products, or services, including where those data are collected from different devices.
(D) Categories of Personal Data we Process
|Summary – Categories of Personal Data we Process|
|We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.|
We Process the following categories of Personal Data about you:
- Personal details: given name(s); preferred name; and photograph.
- Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
- Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
- Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Purchase details: records of purchases and prices; consignee name, address, contact telephone number and email address.
- Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques. For online payments, we will only process: your card number; your card expiry date and the visual cryptogram
- Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information.
- Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
- Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
- Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms and your social media user name if you participate in one of our awards or competitions using your social media account.
(E) Sensitive Personal Data
|Summary – Sensitive Personal Data|
|We do not seek to collect or otherwise Process Sensitive Personal Data. If you share Sensitive Personal Data with us we will only Process it if it is necessary for one to the purposes of processing described at Section (F) and only with your explicit consent, otherwise we will securely dispose of it upon receipt.|
(F) Purposes of Processing and legal bases for Processing
|Summary – Purposes of Processing and legal bases for Processing|
|We Process Personal Data for the following purposes: providing our products, and services to you; operating our Sites; improving our Sites, products and services; conducting surveys; running awards and competitions; operating our business; send marketing communications; sending product safety communications; conducting investigations where necessary; compliance with applicable law;;recruitment and job applications, ensuring the safety of visitors to our promises and the physical security of our premises|
The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
|Processing Purposes||Legal basis for Processing|
|Provision of products, and services: providing you with products and services which you have purchased, including communicating with you about your order and making arrangement for shipping and delivery.||The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us.|
|Operating our Sites: operating and managing our Sites, including understanding how they are used; identifying technical issues; and securing our Sites.||We have a legitimate interest in carrying out the Processing for the purpose understanding how our sites are used, the regional locations of visitors and the user experience and to support and secure our Sites (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).|
|Improving our Sites, products, and services: identifying opportunities to improve Sites, our products, or our services; and creating new Sites, products, or services.||We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).|
|Surveys: engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.||We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).|
|Awards and competitions: administering awards and competitions we operate, including assessing your entry, selecting finalists and choosing a winner based on the criteria of the specific award or competition.||We have a legitimate interest in carrying out the Processing for the managing awards and competitions that we operate (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).|
|Operating our business: operating and managing our business including for the purposes of sales and financial management; maintaining internal records; carrying out organisational and administrative tasks; managing suppliers and for corporate auditing||We have a legitimate interest in carrying out the Processing for the purpose of operating and managing our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).|
|Marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, including news, promotions and information about our awards and competitions. ||We have a legitimate interest in sending you marketing communications (to the extent permitted by law in the country in which you reside) (provided such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).|
|Product safety communications: sending you communications in relation to product safety, including product recalls and product safety advisory notices.||We have a legitimate interest in carrying out the Processing for the purpose of ensuring the safety, and proper use, of our products (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or Depending on the country in which you reside, the Processing may be necessary for compliance with a legal obligation.|
|Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.||The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).|
|Legal proceedings: establishing, exercising and defending legal rights.||The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).|
|Legal compliance: compliance with our legal and regulatory obligations under applicable law.||The Processing is necessary for compliance with a legal obligation.|
|Fraud prevention: Detecting, preventing and investigating fraud.||The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).|
|Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.||The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).|
|Visitor safety: ensuring the health and safety of visitors to our premises including asking you to sign-in when you visit us.||We have a legitimate interest in carrying out the Processing for the purpose of ensuring the health and safety of visitors to our premises; or Depending on the country in which you reside, the Processing may be necessary for compliance with a legal obligation.|
|Premises security: ensuring the physical security of our premises including keeping records of visits to our premises recording CCTV images.||We have a legitimate interest in carrying out the Processing for the purpose of ensuring physical security of our premises.|
(G) Disclosure of Personal Data to third parties
|Summary – Disclosure of Personal Data to third parties|
|We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites.|
We disclose Personal Data to other entities within the PDC group, for legitimate business purposes and the operation of our Sites, products, or services to you), in accordance with applicable law. In addition, we disclose Personal Data to:
- you and, where appropriate, your appointed representatives;
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- accountants, auditors, lawyers and other outside professional advisors to PDC, subject to binding contractual obligations of confidentiality;
- third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
|Summary – Profiling|
|Personal Data are subject to Profiling.|
We may Process Personal Data collected using cookies and tracking technologies on our Sites for the purposes of Profiling in order to provide you with targeted advertising as described in the table below. We Process your Personal Data for these purposes with your prior consent if you agree to our use on cookies on one of our Sites. You can withdraw your consent at any time through our consent management platform which is displayed on our Sites
|Profiling activity||Logic of the Profiling activity||Consequences for you|
|When a user visits our Sites, marketing campaigns may run using cookies and other tracking technologies to collect information about users’ online activities (behavioral tracking) for advertising retargeting on certain social media websites.||Enables us to retarget advertising to online consumers based on the web behaviors on our Sites.||This Profiling activity means that you will receive retargeted advertising relevant to your interests in our Sites.|
(I) International transfer of Personal Data
|Summary – International transfer of Personal Data|
|We transfer Personal Data to recipients in other countries. In particular, we transfer Personal Data to PDC group companies in the United States. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.|
Because of the international nature of our business, we transfer Personal Data within the PDC group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below.
Please note that when you transfer any Personal Data directly to a PDC entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.
(J) Data security
|Summary – Data security|
|We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.|
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
(K) Data accuracy
|Summary – Data accuracy|
|We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.|
We take every reasonable step to ensure that:
- your Personal Data that we Process are accurate and, where necessary, kept up to date; and
- any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
(L) Data minimisation
|Summary – Data minimisation|
|We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.|
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.
(M) Data retention
|Summary – Data retention|
|We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.|
We take every reasonable step to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
(1) we will retain Personal Data in a form that permits identification only for as long as:
(a) we maintain an ongoing relationship with you (e.g., where you create an account with us, or where you are lawfully included in our mailing list and have not unsubscribed); or
(b) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),
(2) the duration of:
(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),
(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
- permanently delete or destroy the relevant Personal Data; or
- anonymize the relevant Personal Data.
(N) Your legal rights
|Summary – Your legal rights|
|Subject to applicable law, you may have a number of rights, including: the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure of your Personal Data, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.|
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
- the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
- the right to request rectification of any inaccuracies in your Relevant Personal Data;
- the right to request, on legitimate grounds:
- erasure of your Relevant Personal Data; or
- restriction of Processing of your Relevant Personal Data;
- the right to object on grounds relating to your particular situation to the processing of your Relevant Personal Data;
- the right to the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes;
- the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable (“right to portability”);
- where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
- the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).
In France you also have:
- the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data, except where we are obliged to Process such Personal Data in compliance with our legal obligations or where this is forbidden by a statutory provision; and
- under specific conditions, the right to give instructions on how you would like us to store, delete or share your personal data after your death. Please contact us for more information in this respect.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
- if we have reasonable doubts concerning your identity, we may ask you to provide evidence of your identity before we can give effect to these rights; and
- where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
(O) Cookies and similar technologies
|Summary – Cookies and similar technologies|
(Q) Direct marketing
|Summary – Direct marketing|
|We Process Personal Data to contact you with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe for free at any time.|
We process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. If we provide Sites, products, or services to you, we may send information to you regarding our Sites, products, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, products, or services you have requested.
(R) Details of Controllers
|Summary – Details of Controllers|
|There are several PDC entities that act as Controllers for the purposes of this Privacy Notice.|
For the purposes of this Notice, the relevant Controllers are:
|Controller entity||Contact details|
|PDC Brands (Original Additions (Beauty Products) Ltd)||Data Protection Officer|
1st Floor Charter Building
Alternatively, you may contact us using our online Contact Us form.
- “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
- “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons, pixel tags, and clear GIFs.
- “Controller” means the entity that decides how and why Personal Data are Processed. In EEA jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- “EEA” means the European Economic Area.
- “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
- “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
- “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data for the purpose of uniquely identifying a natural person, sexual life or sexual orientation, or any other information that are deemed to be sensitive under applicable national law.
- “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
- “Site” means any website operated, or maintained, by us or on our behalf.