Privacy Policy

This policy is effective from November 2019.

Raisio Ireland Limited (”We”) are committed to protecting and respecting your privacy.

This policy (and any other documents referred to on it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us through your interactions with our website, www.benecol.ie. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

This website is operated by Raisio Ireland Limited, a registered company with an address at 51 Bracken Road, Sandyford, Dublin 18, Ireland. We use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and we are responsible as “controller” of that personal information for the purposes of those laws.

Throughout our website we may link to other websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

This website is not intended for use by children under the age of 16 and we do not knowingly collect or use personal information relating to children.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

• Information you give us. This is information about you that you give us by filling in forms on our site www.benecol.ie (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our site, register to become a member of our site, search for a product, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, send us feedback and if you report a problem with our site. The information you give us may include your name, address, contact details, e-mail address and phone number, interests, date of birth, other information relevant to customer events, offers and surveys, details of feedback you give us by phone, email, post or via social media and your account details such as username and login details (if applicable). We collect this personal information from you directly, such as when you register with us or contact us. We also collect personal information from you indirectly, such as your browsing activity while on our website (see our cookie policy for more information).

We do not ask you to give us 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.

When you contact us with a query or complaint about our products and services, you may voluntarily provide us with information concerning your health. We will only use this information with your consent and for the purpose of handling your query or complaint. You have the right, free of charge, to withdraw your consent to us using information concerning your health in this way by contacting us using the details in the section entitled “Contacting Us”.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 COOKIES AND OTHER SIMILAR TECHNOLOGIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies and other similar technologies we use and the purposes for which we use them see our Cookie policy.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• Information you give to us. We will use this information:
  • to understand your needs and provide you with a better service;
  • to provide you with information about other goods and services we offer that are similar to those that you have enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you or to conduct marketing studies and campaigns. We will only send you marketing communications by electronic means if you have consented to this.;
  • to notify you about changes to our site or to our services that may affect you;
  • to improve our services; and
  • to ensure that content from our site is presented in the most effective manner for you and for your computer.
• Information we collect about you. We will use this information:
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods that may interest you or them.
• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose. You can withdraw consent free of charge at any time
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section section 7 of the Companies Act 2014.
• Selected third parties including:
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
  • Third Party Service Providers: We may share your personal information with third party service provides that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, analytics and search engine providers that assist us in the improvement and optimisation of our site, our technical support providers for our online services, printers, lawyers and other business advisors, marketing companies who carry out marketing campaigns on our behalf, providers of newsletter distribution services and providers of security and administration services; and
  • other third parties in order to share click data.

We will disclose your personal information to third parties:

• If Raisio Ireland Limited or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply any terms relating to our site or any other agreement; or to protect the rights, property, or safety of Raisio Ireland Limited or any member of our corporate group, our customers, or others.

WHERE WE STORE YOUR PERSONAL INFORMATION

We may transfer your personal information to countries outside the European Economic Area (“EEA”). Where there is no adequacy decision by the European Commission in respect of any such country that means that that country is deemed not to provide an adequate level of protection for your data. However to ensure your personal information does receive an adequate level of protection we will in such circumstances put in place appropriate measures such as the use of model contractual clauses as approved by the European Commission to ensure that your personal information is treated by those third parties in ways that are consistent with respect to EEA and Irish laws on data protection.

We may transfer your personal information to our email marketing platform, Mailchimp, whose operations are located in the United States of America.

The United States of America do not have the same data protection laws as Ireland and EEA. Whilst the European Commission has not given a formal decision that the United States of America provides an adequate level of protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information is protected in accordance with the EU-US Privacy Shield framework which is designed to safeguard your privacy rights.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

INFORMATION ABOUT OUR USE OF COOKIES

Our site uses cookies to distinguish you from other users of the site. We may also use other technologies such as google tagging, web tags and pixel tags. These tags send a message to us that cause a cookie to be dropped or a mobile identifier to be accessed. The use of cookies and other similar technologies helps us to provide you with a good experience when you browse our site and also allows us to improve our site. To find out more about how we use cookies and other similar technologies and how you can manage your preferences, please see our cookie policy.

MARKETING

We would like to send you information about products and services, competitions and other special offers which may be of interest to you. Where we have your consent, we may do this by post, email, telephone, text message (SMS) or automated call.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time free of charge by:

• contacting us (see below); or
• using the “unsubscribe” link in each communication we send to you.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights which you can exercise free of charge. In summary those include rights to:

• fair processing of information and transparency over how we use your personal information;
• access to your personal information and to certain other supplementary information that this privacy policy is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object at any time to processing of personal information concerning you;
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your personal information;
• otherwise restrict our processing of your personal information in certain circumstances.

These rights are in some circumstances limited by data protection legislation.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the Office of the Data Protection Commission on individuals’ rights under the General Data Protection Regulation: www.dataprotection.ie.

If you would like to exercise any of those rights, please:

• email or write to us by using the details set out below;
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport, and
• let us know the information to which your request relates.

We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will explain why.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

ACCESS TO INFORMATION

Data protection laws give you the right to access information held about you free of charge. In some circumstances, the data protection laws permit us to charge a reasonable fee in providing access to information held about you, for example, where your request is repetitive or excessive.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CONTACTING US

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Raisio Ireland, 51 Bracken Road, Sandyford, Dublin 18 or at benecol@sitel.com.

We hope that we can resolve any query or concern you raise about our use of your information.

COMPLAINT TO DATA PROTECTION COMMISSION

The General Data Protection Regulation also gives you 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. The supervisory authority in Ireland is the Office of the Data Protection Commission who may be contacted at www.dataprotection.ie or telephone: +353 57 8684800.