This Privacy Policy governs the processing of your personal data by the Ansell group of companies (referred to as: “Ansell”, “we”, “us”, “our”) captured through the following methods:
· when you visit our global and local websites (the “Website”);
· when you communicate with us via e-mail, telephone, fax and/or social media channels; and/or
· through other online and offline channels.
If you want more information on how we process personal data via cookies, social plugins and other types of tracking technology, please refer to our Cookie Policy.
1.1. You can contact us via e-mail at privacy@ansell.com.
1.2. A reference in this Privacy Policy to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.
1.3. Ansell reserves the right to from time to time modify, change or amend this Privacy Policy at its own discretion. Such modification, change or amendment will be communicated via the Website. If you do not accept the modifications, changes or amendments, you are not allowed to use our Website anymore.
2.1. Whenever you use our Website and social media channels, we collect the following information in accordance with our Cookie Policy:
· 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 behaviour, 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 fill out a contact form (either offline or via our Website), directly make a purchase with us, apply for a job, 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, and your billing information, including your address and credit card number, if you make purchases with us;
· 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.), as well your preferences as to the communication medium used;
· 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: any other personal data you choose to provide to us.
2.3. We receive all the personal data listed above directly from you. We may also receive additional information about your preferences and surfing behaviour from our partners, including our business and commercial partners– who collect your personal data from you when you interact with them. When dealing with such third parties, these third parties will process your personal data in accordance with their own privacy policy.
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 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:
(a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party;
(b) a threat to the security or integrity of the Website, social media channels or other communication channels;
(c) 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
(d) 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.
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.
5.2. Ansell may share your personal data with other entities within the Ansell group for the purposes of sales, marketing and financial data analysis. We will ensure that all Ansell entities will take due care that all processing of your personal data is in line with this Privacy Policy.
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.
5.5. When it comes to mergers, acquisitions or bankruptcy liquidation, Ansell will require new companies and organizations that hold your personal data to continue to be bound by this Privacy Policy, otherwise we will ask the companies and organizations to re-seek consent from you.
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:
· customizing your unique profile based on relevant characteristics as outlined in Article 2 of this Privacy Policy; and
· 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. 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. Please understand, however, that safety and security are best effort obligations which can never be guaranteed.
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 privacy@ansell.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:
+1-800-800-0444 (NA)
+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 honour 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.