· when you visit our global and local websites (the “Website”);
· when you communicate with us via e-mail, text, telephone, fax, social media channels, and/or other electronic messages through this Website and/or
· through other online and offline channels.
Important note for individuals located in the European Economic Area (namely the European Union (EU), Iceland, Liechtenstein and Norway), [as well as in Switzerland and United Kingdom]:
- this front section, which sets out the general principles applicable to the processing of your personal data by the Ansell group of companies in general; and
- an additional EU addendum, which provides additional important information regarding the processing of your personal data if you are located in the EEA, Switzerland or UK, or if your personal data is processed by one of Ansell group companies established in one of these jurisdictions or is otherwise subject to GDPR (the "EU Addendum").
1.1. You can contact us via e-mail at firstname.lastname@example.org.
· Geolocation Information: this includes technical information associated with the device you use, such as your IP-address, browser type, geographical location and operating system; and
· Internet/Electronic Activity Information: this includes information concerning your browsing behavior, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
When using our Website and social media channels, you may do so anonymously or pseudonymously, except where you contact us as set out below.
2.2. When you create a user account, fill out a contact form (either offline or via our Website), subscribe to our notifications, respond to our surveys, post material to be published or displayed, directly make a purchase with us, apply for a job, interact with our applications on third-party websites (if those applications include links to this Policy), participate in promotions such as sweepstakes or contests, or contact us in person (such as at trade conferences) via e-mail, telephone, fax or social media channels, we collect:
· Identifier Information and/or Information Protected Against Security Breaches: this includes information you provide us with, such as name, e-mail address, postal address, phone number, mobile telephone number, your country, and the company you work for, as well as your financial account information if you make purchases with us, including your billing address, delivery address, credit/debit card number, expiration date, security code, or other billing/payment information;
· Commercial Information: the content of your communication or enquiry and the technical details of the communication itself (with whom you correspond at our end, date, time, etc.), your preferences as to the communication medium used, your search queries on our Website, details of transactions you carry out through our Website and of the fulfilment of your orders;
· Professional, Employment, or Education Related Information: this includes job application information, such as your education and work history, skills and qualifications for a particular position;
· Public Information: this includes publicly available information of your profile on social media channels;
· Other: this includes any other personal data you choose to provide to us.
2.4. Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal data to or on our Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.
3.1. Ansell processes your personal data to provide you in a personalized and efficient way the information, products and services you request via the Website, by e-mail, telephone, fax or social media channels.
3.2. Ansell processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Ansell and selected partners.
3.3. Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, Ansell will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels that you have explicitly consented to receive.
3.4. Ansell processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
Ansell may transfer your personal data to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our social media channels or other communication with us.
3.5. Ansell processes your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services or to develop new products and services.
3.6. Ansell processes your personal data to fulfill the purpose for which you provide it, or for any other purpose disclosed by us when you provide the information.
3.7. Ansell may process your personal data to preserve the legitimate interests of Ansell, its partners or a third party if your registration with or use of the Website, social media channels or other communication channels can be considered:
(c) a threat to the security or integrity of the Website, social media channels or other communication channels;
(d) a danger to the Website, social media channels or other communication channels or any of Ansell’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code; or
(e) in any way hateful, obscene, discriminating, racist slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
4.1. The processing of your personal data for the purpose outlined in Article 3.3. above is based on your consent.
4.2. If your personal data is processed for the purpose outlined in Article 3.1. and in order to take steps prior to entering into a contract with us, we may process your personal data as necessary for the performance of that contract, or in the process of entering into that contract.
4.3. For the purpose mentioned in Article 3.4., the processing of your personal data is necessary for Ansell’s legal obligations.
4.4. For the purposes mentioned in the Articles 3.1, 3.2, 3.5. and 3.6. above, the processing of your personal data is necessary for purposes of our legitimate interests, such as:
· continuous improvements of the Ansell Website, social media channels, products and services to ensure that you have the best experience possible;
· keeping our Website, social media channels, products and services safe from misuse and illegal activity; and
· marketing and promotion of our products, services, brands and overall successful commercialization of our products and services.
5.1. Ansell relies on third party processors to provide you our Website and to process your personal data on our behalf for the purposes set out in Article 3 above. These third-party processors are only allowed to process your personal data on behalf of Ansell upon explicit written instruction from us solely for the purposes for which we disclose it to them, and are contractually obligated to keep your personal data confidential.
Ansell warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.
5.3. Ansell may publicly disclose your personal data in cases of law, legal proceedings, litigation or mandatory requirements of the competent government authorities.
5.4. Ansell does not send your personal data in an identifiable manner to any third party other than those mentioned in Articles 5.1., 5.2 and 5.3, without your explicit permission to do so. Ansell may send anonymized data to other organizations that may use such data for improving products and services as well as for the purposes of tailoring the marketing, displaying and selling of those goods and services.
6.1. Ansell may need to transfer your personal data to other Ansell entities or third parties who process personal data on our behalf to locations outside the jurisdiction in which you provided it.
If you are based within the European Economic Area (“EEA”), please note that where necessary to provide the products and services, we may transfer personal data to Ansell entities located in countries outside of the EEA. All Ansell entities have signed a data transfer agreement which is based on EU standard contractual clauses to ensure we comply with our legal and regulatory obligations in relation to personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for personal data.
6.2. Ansell may transfer anonymized and/or aggregated data to organizations outside the jurisdiction in which you provide it. Should such transfer take place, Ansell will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
6.3. Ansell holds your personal data both electronically and/or in hard copy form. We may store your information on our own premises or the premises of our third-party processors or other service providers. We will protect personal data we keep in accordance with Article 7.4 below.
7.1. Ansell does its utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3 above.
7.2. Your personal data is only processed for as long as needed to achieve the purposes listed under Article 3 above or up until such time where you withdraw your consent. Withdrawing your consent may mean that you can no longer use all or part of our Website. Ansell will de-identify your personal data when it is no longer necessary for the purposes outlined in Article 3 above, unless there is:
· an overriding interest of Ansell, or any other third party, in keeping the personal data identifiable; and/or
· a legal or regulatory obligation or a judicial or administrative order that prevents Ansell from de-identifying them.
7.3. You understand that an essential aspect of our marketing efforts is about making our marketing materials more relevant to you. Ansell does this by:
· using this profile to provide you with communications, promotions, offerings, newsletters and other advertisements about products and services that may interest you.
7.4. Ansell will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. Access by Ansell personnel or its third-party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
7.5. If you are registered to receive communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletter and other advertisements by following the opt-out link provided in such communications.
8.1. You have the right to request access to all of your personal data processed by Ansell. Each request must specify: (a) which processing activity you wish to exercise your right to access and (b) which data categories you wish to gain access to. Ansell reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Ansell.
8.2. You have the right to ask that any inaccuracies in your personal data held by Ansell be corrected free of charge. If you submit a request for correction, your request needs to be accompanied by proof of the inaccuracy.
8.3. You have the right to withdraw your earlier consent for the processing of your personal data.
8.4. You have the right to request that your personal data is deleted if such data is no longer required for the purposes set out in Article 3 above or if you withdraw your consent for its processing. However, please keep in mind that a request for deletion will be evaluated by Ansell against:
· the overriding interests of Ansell or any other third party; and
· legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion, you can also ask that Ansell limit the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data is no longer needed for the purposes listed under Article 3 above.
8.5. You have the right to oppose the processing of personal data if you prove that there are serious and justified reasons that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
8.6. You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.
8.7. If Ansell sells your personal data to third parties, you have the right, at any time, to direct us not to sell your personal data. Ansell does not sell personal data.
8.8. You have the right to be free from discrimination or retaliation for exercising any of your rights as described above.
9.1. If you wish to submit a request to exercise one or more of the rights listed above, you can do so using one of the following methods:
· Send an e-mail to email@example.com. Please note that an e-mail requesting to exercise a right will not be taken as a consent to process your personal data beyond what is required for handling your request.
· Call us:
+613 9270 7270 (APAC)
+1800 337 041 (AU/NZ)
+32 2 528 74 00 (EMEA)
· Write to us at Level 3, 678 Victoria Street, Richmond VIC, Australia 3121, ATTN: PRIVACY
All requests submitted through any of these methods should:
· clearly state which right you wish to exercise and the reasons for it, if required;
· be dated and signed; and
· be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you contact us via phone, Ansell may ask you for your signed confirmation and proof of identity.
Ansell will promptly inform you when we receive your request. If the request is valid, Ansell shall honor it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
If you have any complaint regarding the processing of your personal data by Ansell, you may contact us through any of the methods listed above. If you remain unsatisfied with our response, you may file a complaint with the relevant regulator or data protection authority in your country.
9.2. In order to comply with certain requirements of relevant laws and regulations, Ansell will not be able to respond to your request in circumstances:
a. that directly relate to national security and national defense security;
b. that directly relate to public safety, public health and major public interests;
c. that directly relate to criminal investigations, prosecutions, trials and execution of judgments.
d. where there is ample evidence that you have subjective malice or abuse of rights.
e. where, in response to your request, you will cause serious damage to the legitimate rights and interests of you or other individuals and organizations; or
f. that involve business secrets.
If you are located in the EEA, and the processing of your personal data relates to the offering of our Websites, goods or services or the monitoring of your behaviour in the EEA (for example, through our EU web shop at www.shop.ansell.com), or the processing of your personal data is carried out in the context of the activities of one of Ansell group companies established in the EEA, as identified under the Section "Controller of your personal data" below (Ansell, we, us), you may have additional rights under the EU General Data Protection Regulation (GDPR) and implementing national laws. We invite you to read this EU Addendum which contains important additional information about the processing of your personal data.
Under the GDPR, the identity and contact details of the data controller and, where applicable, of the controller's representative, must be provided. In general, the data controller of your personal data is the Ansell company that is operating the Website(s) or providing the relevant product or services to you. For the purpose of the EU web shop www.shop.ansell.com, this is Ansell Healthcare Europe NV, a company based in Belgium, with registered office at Boulevard International 55, 1070 Anderlecht, Belgium, VAT BE 0437.593.328 RPR/RPM Brussels. You will find further details under the "How to Contact us section" below.
Under the GDPR, the identity and contact details of the data controller and, where applicable, of the controller's representative, must be provided. In general, the data controller of your personal data is the Ansell company that is operating the Website(s) or providing the relevant product or services to you. For the purpose of the EU web shop www.shop.ansell.com, this is Ansell Healthcare Europe NV, a company based in Belgium, with registered office at Boulevard International 55, 1070 Anderlecht, Belgium, VAT BE 0437.593.328 RPR/RPM Brussels. You will find further details under the "How to Contact us" section below.
In general, Ansell will collect your prior consent in order to process your personal data where required under applicable law. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
When we rely on our legitimate interests as legal basis for the processing, we carry out a balancing test between our own interests and your interests and fundamental rights and freedoms, which can be obtained by contacting us as described below.
You can obtain further information regarding the recipients of your personal data by contacting us at our contact details below.
Any transfer of personal data to one of the above recipients located in a country outside the EEA that is not recognized as providing an adequate level of data protection, will be made on the basis of appropriate safeguards, in particular (i) data transfer agreement(s) conforming to the EU Commission's standard contractual clauses for the transfer of data to third countries (Article 46, 2., (c) of the GDPR), or (ii) other appropriate safeguards or derogations in accordance with applicable data protection law (Articles 46 to 49 GDPR). You can obtain a copy of these appropriate safeguards by contacting us as described below.
You have a number of rights under the GDPR and implementing national laws, as follows. Please note that the exercise of these rights may be subject to certain limitations and conditions as set out in the applicable law.
Right of access: You have the right to request access to your personal data processed by Ansell. To the extent permitted by applicable law, in order to facilitate the management of your request, we may ask you to specify: (a) which processing activity you wish to exercise your right to access and (b) which data categories you wish to gain access to. Ansell will provide a copy of the personal data undergoing processing. If you request more than one copy of the Personal Data processed, Ansell may charge a reasonable fee, taking into account the administrative costs. In any case, Ansell must take into account the rights and freedoms of others, so this right is not absolute.
Right to rectification: You have the right to ask that any inaccuracies in your personal data held by Ansell be corrected free of charge. Depending on the purpose of processing, you also have the right to request that incomplete personal data be completed, included by means of providing a supplementary statement.
Right of erasure: In certain circumstances, as defined by the applicable data protection legislation, you have the right to request that your personal data is deleted, notably if such data is no longer required for the purposes set out in Article 3 above, if you withdraw your consent for its processing, if your personal data has been unlawfully processed, or if you have objected to the processing and we have no overriding legitimate grounds for the processing. However, please keep in mind that a request for deletion will be evaluated by Ansell and may not apply to the extent the processing is necessary, notably:
· for compliance with a legal obligation which requires processing under applicable law which we are subject to or for the performance of a task carried out in the public interest; or
· for the establishment, exercise or defence of legal claims.
Right to restriction of processing: In certain circumstances, as defined by the applicable data protection legislation, instead of deletion, you can also ask the restriction of the processing of your personal data where, notably, one of the following applies (a) you contest the accuracy of the data, (b) the processing is unlawful and you oppose the deletion of your data, or (c) the data is no longer needed for the purposes listed under Article 3 above but are required by you for the establishment, exercise or defence of legal claims. In this case, your personal data, with the exception of storage, may only be processed with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of substantial public interest.
Right of objection: In the circumstances defined by the applicable data protection law, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data and we may be required to no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
Right to object to direct marketing When your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such direct marketing purposes (including profiling insofar as it relates to such direct marketing). However, if the intended processing qualifies as direct marketing, you have the right to oppose, at any time, to such processing without justification (including profiling insofar as it relates to such direct marketing).
Right to data portability: In certain circumstances, as defined by the applicable data protection legislation, you have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us and you may also have the right to transfer such personal data to another data controller or request Ansell to transfer such data directly to another data controller to the extent this is technically possible.
Right to lodge a complaint: You have the right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes applicable data protection law. For details about the competent supervisory authority in your jurisdiction, see https://edpb.europa.eu/about-edpb/board/members_en.
In the EEA, you can contact us at:Ansell Healthcare Europe NV