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Raisio ‘Believe in Benecol’ campaign Privacy Statement
Raisio plc and other Raisio Group companies (hereinafter referred to as “Raisio”, “we” or “us”) protect the privacy of people participating in the ‘Believe in Benecol’ campaign (“Campaign”) in accordance with the terms and conditions of this Privacy Statement. The Privacy Statement applies to all activities in connection with the Campaign with which Raisio collects personal information.
We take your privacy very seriously. Please read this Privacy Statement carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Once you have read and understood this Privacy Statement, please confirm that you have done so by signing and returning the attached copy to a member of the Benecol team.
What personal information do we collect?
We need to ask you for certain personal information so that we can determine your eligibility to participate in the Campaign, and for the requirements of the campaign itself.
We may collect and use the following personal information about you:
your name and contact information, including email address and telephone number;
your profession and work place;
your date of birth; and
certain health information.
The personal information is required in respect of the Campaign. If you do not provide personal information we ask for, it may delay or prevent us from carrying out the Campaign in respect of you.
We collect most of this personal information directly from you via our “Believe in Benecol” consent form.
We store the personal information that you have given us, as follows:
name, email address, phone number, mailing address, date of birth, language, profession
your health data including but not limited to cholesterol level, health concerns, family history
your consents and prohibitions
your participation in our campaign including all communications during the course of the campaign
your contacts, messages and feedback
your diet information you have given us for the purpose of our events or campaigns.
We will only use this information for the purpose for which you have given it.
In principle, Raisio does not collect children’s personal information. Participants in the Campaign must be at least 18 years old.
How do we use the personal information?
Under data protection law, we can only use your personal information if we have a proper reason for doing so. For example:
for the performance of a contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party;
where you have given consent; or
to comply with our legal and regulatory obligations.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
By signing the “Believe in Benecol” consent form, you are consenting to us using your personal information for the following purposes:
to determine eligibility to participate in the Campaign;
for the purpose of the Campaign and all activities required to implement the Campaign;
to report the findings of the Campaign to media and healthcare professional audiences;
to maintain our contact with you throughout the Campaign;
to contact you about any future activities related to the Campaign;
to improve our products and services, for example the processing of feedback.
Your personal information will be used for the above purposes only and no other purposes without your prior written consent.
Where your personal information is held
Information may be held at our offices and those of the Raisio Group Companies, third party agencies, service providers, representatives and agents as described in this Privacy Statement.
Information retention
We will keep your personal information for the period of time necessary for the purpose stated in this Privacy Statement. Thereafter, we will only keep your personal information for so long as is necessary:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly; and/or
to keep records required by law.
Different retention periods apply for different types of personal information.
We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Statement.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transfer or disclosure of personal information
We routinely share personal information with:
Raisio Group Companies;
potential buyers of some or all of our business or during re-structuring. Usually information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations; and
third parties as detailed below.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
So that we can implement the Campaign, we may transfer your personal information to such authorised third parties who process information on our behalf on the basis of these terms of privacy and legal agreements. These parties include:
parties conducting marketing studies and campaigns;
transport companies or mailing service providers;
technical support providers.
We only allow such third parties to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on such third parties to ensure they can only use your personal information to provide services to us and you.
If we transfer your personal information outside the European Union or the European Economic Area (EEA), the transfer will be made using appropriate agreements between us and the processor/transferee, such as the standard contractual clauses established by the European Commission.
We will not share your personal information with any other third party.
Protection of personal information
Raisio protects the personal information against destruction, loss or alteration, unauthorised disclosure or access as well as other unlawful or unauthorised processing. The measures include, without limitation, preventing unauthorised access to our systems through a firewall and other protective means. Only specifically appointed employees can access personal information and have the right to process them. This also applies to the third parties operating on our behalf or based on our assignment. All these parties are bound by confidentiality obligations.
Your rights related to the personal information processing
You have rights relating to the processing of your personal information unless otherwise required under applicable law.
You have the right:
to access your personal information in our records and to have a copy of them;
to have your inaccurate personal information rectified and modified;
to request for the removal of your personal information, to restrict its use and to object the processing of your information;
to withdraw your consent to the extent that your personal information are processed based on your consent. However, we may have the right to process your information on another legitimate basis. Furthermore, the withdrawal of consent has no effect on the lawfulness of processing occurred before the reception of withdrawal;
to require the transfer of your data to you or another controller (in certain situations) in a structured, commonly used and machine-readable format;
to file a complaint with the supervisory authority if you believe that your personal information has not been processed in accordance with this Privacy Statement or applicable law.
The supervisory authority’s contact information: UK Information Commissioner on 0303 1231113.
For further information on each of the above rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’’ rights under the General Data Protection Regulation.
Before you can use these rights, we may have to ask for additional information in order to confirm your identity and address. For example, a copy of your driving licence or passport and a recent utility or credit card bill. Please also let us know which right you want to exercise and the information to which your request relates.
We do not store this additional information and it will be removed when we have confirmed your identity.
In case you want to use your rights, please contact us at the address below. We will process your request as soon as possible and get back to you within 30 days as provided by law.
Changes in the Privacy Statement
We reserve the right to change this Privacy Statement when the legislation changes or to develop its business operations. If the changes materially affect the Campaign participants, we will notify individuals by sending an email.
Contact information
The Controller’s contact information:
Raisio plc
Visiting address: Raisionkaari 55, 21200 Raisio, Finland
Postal address: P.O. Box 101, FI-21201 Raisio, Finland
Telephone: +358 2 443 2111
In matters related to data protection, please contact our customer service by phone +358 2 443 2022 on weekdays 8-11. At other times, you can leave a message on the answering machine or send a message to privacy(at)raisio.com.
How to complain
We hope that we can resolve any query or concern you may raise about your use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
Details of the supervisory authority in the UK are set out above.