Privacy Statement

VESTACY HOME - GLOBAL PRIVACY NOTICE

Vestacy

Welcome to Vestacy's Global Privacy Notice ("Privacy Notice").

We are committed to protecting your privacy. This Privacy Notice applies to all of our brands globally and explains how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from under your local law.

In this Privacy Notice "we", "us" and "our" refers to all the companies of the Vestacy including Vestacy. As this Privacy Notice applies globally, there may be differences in how we collect, use or disclose your Personal Information from country to country, in which case we will inform you about any specific processing activities that take place in your country.

Your Personal Information is controlled by Vestacy (having a registered office at 103-105 Bath Road, Slough, Berkshire, SL1 3UH, United Kingdom). As regards this website, Vestacy is the data controller.

For more information about us, our local companies, our brands and our presence in your jurisdiction, please visit www.vestacy.com.

Definitions

By "Personal Information" (in some countries referred to as "personal data" or "personally identifiable information") we mean any information relating to an identified or identifiable individual. This is broader than just information of a personal or private nature, and also includes information such as your name, date of birth, and e-mail address. Please see Section 3 below for what Personal Information is obtained from you.

By Sensitive Personal Information (in some countries referred to as sensitive personal information or special categories of data) we mean any Personal Information relating to an individuals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data processed for the purpose of uniquely identifying that individual, data concerning health, or data concerning an individuals sex life or sexual orientation. It also includes information about an individuals criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws.

1. Scope of our Privacy Notice

Our Privacy Notice applies to all Personal Information we collect, use, share or otherwise process through our business activities, both online and offline, which display, link or refer to this Privacy Notice, including:

our websites;
our official social media pages;
our e-mails;
our apps;
our online and offline campaigns; and
your conversations or correspondence with our representatives.

Throughout this document, we will refer to our online activities as "Sites" and to our offline activities as "Services".

You should be aware of the fact that our Sites may contain hyperlinks to third party websites, apps, etc. which are not controlled by us and which are not covered by this Privacy Notice. We have no responsibility or liability for the content and activities of these third party websites, apps, etc. As these third parties may collect your Personal Information, we suggest that you consult the privacy policies of these third parties to learn more about their use of your Personal Information.

Our websites make use of cookies. For more information on this subject, please also consult our Cookies Policy.

Further, when using our Sites or Services, please always also read our Terms of Use.

2. Fair and lawful processing

We process your Personal Information for the below listed purposes on the basis of your consent, unless stated otherwise. In some cases, where required by local law, we may ask for your explicit consent for processing your Personal Information for a specific purpose.

We only collect, use, disclose or otherwise process your Personal Information where it is fair and lawful to do so.

In many cases providing your Personal Information to us is necessary for the performance of your contract with us; if you do not wish to provide your Personal Information to us, we may not be able to provide you with the products and services you have requested from us.

3. How do we obtain your Personal Information?

Vestacy collects Personal Information that is reasonably necessary for, or directly related to, Vestacys functions and activities which includes the marketing and sale of products to consumers or customers.

Personal Information obtained from you directly

Firstly, we may obtain your Personal Information from you directly, e.g. when you sign up for our newsletters, register on our Sites, buy a product from us, fill out a survey, make a comment or enquiry, post something on our social media pages, subscribe to direct marketing, call our Consumer Relations centre etc.

Personal Information collected this way may include:

name;
address;
e-mail address;
user name;
telephone number (and recordings when you call our consumer line);
credit card or other payment information;
age;
date of birth;
gender;
product purchase and usage information;
complaint or enquiry details;
household information;
information, feedback or content you provide regarding your marketing preferences;
user-generated content, posts and other content you submit to our Sites;
in limited circumstances, information about your family or other individuals that you have provided to us. In such cases, we assume that you have the authority to share any personal information your provide to us about them;
in limited circumstances based on your explicit consent or if the collection is required/authorised under Australian law or if a permitted general situation or permitted health situation exists (as defined in the Privacy Act 1988 (Cth)), Sensitive Personal Information such as information relating to your health (including information related to product usage and medical history), sexual life (and related behavior) and biometrics collected during volunteer consumer research studies (such as facial expression recognition, heart rate and skin condition);
demographic information; or
any other Personal Information you voluntarily provide us with directly.

Personal Information collected automatically

Secondly, some Personal Information may be collected automatically when you visit or use our Sites (and those of our third party service providers acting on our behalf), such as information collected by cookies and other technologies (such as web analytic tools and pixel tags) on our websites. Please also consult our Cookies Policy for more information on how we make use of cookies and other automated means of data collection.

Personal Information collected this way may include:

information about your (mobile) device or your type of browser;
information about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.;
whether you have opened e-mails sent by us to you;
the websites you have visited before arriving at one of our websites;
your IP address;
the hyperlinks you have clicked;
your user name, profile picture, gender, networks and any other information you choose to share when using third party sites (such as when you use the Like functionality on Facebook or the +1 functionality on Google+);
your MAC address;
information you choose to share by using social media tools incorporated in our websites or using your social media log-in details to access certain RB product sites or applications; and
information you share with us about your location. Where we are required to do so by local law, we will only use that information where you have agreed that we can.

Please note that we have no control over third party service providers which may use cookies on our websites.

From time to time, we may also use third party analytics services such as Google Analytics Advertising Features. We may use this technology to obtain an additional set of user data such as the location, gender, and/or age bracket of the website user which does not identify the user. We may also use these technologies to deliver relevant promotional and other targeted information to you on our Website and other third-party websites based on your use of our Website.

Where you have provided your personal information and explicitly consented to receiving digital communications from us, we may include you in our targeting of Custom Audiences (e.g. Facebook Custom Audiences of Google Customer Match).

You may request that you be removed from this level of targeting by contacting us directly (see contact details below).

Each third party advertising partner (e.g. Facebook, Google, AdRoll, etc) offers an opportunity for you to opt out of these features or this level of targeting. For example, you may opt-out of the Google Analytics Advertising Features by changing your settings in Ad Settings, Ad Settings for mobile apps, using the Google Analytics Opt-Out Browser Add-on, or any other means available.

Personal Information obtained from other sources

Lastly, we may also collect Personal Information about you from other sources. These other sources may include:

our trusted business partners;
social media sites;
consumer research organisations;
credit reference agencies;
intermediaries that facilitate data portability; and
other members of our group.

Personal Information collected this way may include your interests such as hobbies and pets, consumer and market research data, purchase behavior, publicly observed data or activities such as blogs, videos, internet postings and user generated content.

4. For which purposes, may we use your Personal Information

We may collect, hold, use, and disclose your Personal Information for our following business purposes:

based on your contract with us, handling and managing your purchase, for instance to communicate to you with respect to your purchase, to process your payments, to deliver the purchased products and services, and to offer you the necessary customer service;
allowing you to participate in promotions, contests, surveys and polls;
allowing you to share information and ideas on our social media pages, forums, blogs and other communication channels, to participate in social sharing and to send messages to a friend through our Sites or the websites of our trusted business partners;
better understanding your needs in order to provide you with more relevant information, analyzing and evaluating our corporate activities, testing, developing and evaluating new products and improving our existing products and services, conducting market research and audits, identifying user trends and examining the degree of effectiveness of our marketing campaigns and degree of satisfaction of our customers;
telling you about our products and services, and sending you promotional materials (such as announcements relating to new products, promotions, savings programs, joint promotions and other programs) relating to our brands and those of our carefully selected trusted business partners, subject to your consent to such marketing where required by local law;
managing our Sites, and tune the experience and content of our Sites to your previous activities on our Sites, in view of personalizing your experience when visiting our Sites;
responding to your complaints, requests or enquiries;
dealing with any product adverse events you report to us;
administering general record keeping;
contacting you to ensure your Personal Information is up to date and accurate; and
meeting legal and regulatory requirements.

Your local law may require us to set out in this Privacy Notice the legal grounds on which we rely in order to process your Personal Information. In such cases, our use of your Personal Information is permitted by law because:

it is necessary for our legitimate interests in the effective delivery of information, services and products to you and in the effective and lawful operation of our business (in each case provided such interests are not overridden by your rights);
it is necessary for taking steps to enter into a contract with you for the products you purchase, or for carrying out our obligations under such a contract;
it is required to satisfy any legal or regulatory obligations that we are subject to; and
in limited circumstances and if required by local law, you have agreed to us processing your Personal Information, such as when you opt in to marketing, or processing with your explicit consent in the case of Sensitive Personal Information, such as health information.

We may create anonymous data records from Personal Information by excluding information (such as your name) that make the data personally identifiable to you. We use this anonymous data to analyse our products and services. We reserve the right to use such anonymous data for any purpose and disclose anonymous data to third parties, including but not limited to our research partners, in our sole discretion.

From time to time, Vestacy received unsolicited personal information. Unsolicited personal information will not be held by us and will be destroyed.

5. To whom we may disclose your Personal Information

Intra-group sharing

Your Personal Information may be shared between the different companies and brands of our group, for the purposes set out in this Privacy Notice. As we have stated above, this Privacy Notice applies to all these companies and brands use of your Personal Information. This means that in providing services we may need to transfer data to another Vestacy office in another country (including Malaysia, New Zealand, European Union, United Kingdom and United States of America) or to other overseas entities such as our agents. We will take all reasonable steps necessary to ensure that any Personal Information transferred overseas is kept securely and in accordance with the Privacy Act 1988 (Cth) by the overseas entity. For more information about us, our companies, our brands and our presence in your jurisdiction, please visit www.vestacy.com.

Third party service providers

We may share your Personal Information with trusted third party service providers who work on our behalf, such as marketing agencies, market research companies, e-commerce fulfilment partners, software, data hosting and other IT service providers, merchants selling Vestacy products, call centres, payment processors, etc. These third party service providers are required not to use your Personal Information other than to provide the services requested by us or otherwise in accordance with our instructions.

Further, web traffic information is disclosed to Google Analytics when you visit our websites. Google stores information across multiple countries. For further information see Google Data Centres and Google Locations.

Other trusted third parties

We may also share your Personal Information with other trusted third parties, such as our business partners, advertisers (where we are permitted to do so) and data exchanges, so that we can offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to deliver customized content and advertising to you when you visit Vestacy websites.

Our websites and/or applications may also allow you to log in using a social network or other third-party account or communicate with us through a social network service provider. An example of a third-party login is Log in with Facebook. Logging into one of our sites with your social network or other third-party account or communicating with us through a social network provider may allow us to gather information that you give us permission to access from that social network or third party. The login and/or communication feature may also transfer information to the social network or third party, such as your username and password, to authenticate you. The social network or third party may also automatically collect information such as your IP address, information about your browser and device, and the address of the web page you are visiting on our site. The login and/or communication feature may also place and read cookies from that third party that may contain a unique identifier the social network or other third party assigns to you. The functionality of, and your use of, the login or communicating through the social network provider is governed by the privacy policy and terms of the party that provided the login and/or communication functionality, rather than this Privacy Notice.

Acquisitions

If another company acquires (part of) our company, business, or our assets, that company may acquire all or part of the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Notice. In the unlikely event of an insolvency, bankruptcy or receivership, your Personal Information may also be transferred as a business asset, subject of applicable law.

Disclosures

6. We may disclose your Personal Information if you have consented to the use or disclosure or if an exception under the Privacy Act 1988 (Cth) applies.

How we protect your Personal Information

We value the trust you place in us.

Vestacy will take reasonable steps to ensure the appropriate technical and organisational measures are implemented to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

When collecting or transferring Sensitive Personal Information we use a variety of additional security technologies and procedures to help protect this information.

The Personal Information you provide us with is stored on computer systems located in controlled facilities overseas, including in Germany, which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.

When we process highly confidential information (such as credit card numbers) over the Internet, we protect it through the use of encryption.

7. Your choices regarding direct marketing

We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our products and services which we believe are useful for you, if you have consented (opted-in) to receive such messages via e-mail or any other electronic channel.

If you do not wish to receive such communications anymore, you will always have the opportunity to "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see our contact information at how to contact us below).

We will inform you before collecting your Personal Information if we intend to use your Personal Information for such a purpose.

8. Your rights

Accessing your Personal Information: You are entitled to access your Personal Information held by us free of charge in the manner requested by you. If you wish to access your Personal Information, please see our contact information at how to contact us below. However, we are not obliged to provide you with access to your Personal Information if by doing so we would reveal Personal Information about another person. We will also take reasonable steps to identify your identity before granting access to your Personal Information.

Correcting your Personal Information: Vestacy will take reasonable steps to ensure that the personal information that we collect, use or disclose is up to date, complete and accurate and relevant. If your Personal Information changes or you wish to correct it, please let us know by contacting us (please see our contact information at how to contact us below) and we will update our records within a reasonable time period after your request is made.

Depending on your location, you may have various rights in relation to your Personal Information. In particular, you may have the right to:

request a copy of Personal Information we hold about you;
ask that we restrict the way in which we use your Personal Information;
ask that we update the Personal Information we hold about you, or correct any Personal Information that you think is incorrect or incomplete;
ask that we delete personal data that we hold about you (the right to be forgotten);
withdraw consent at any time for the future to our processing of your Personal Information (to the extent such processing is based on consent);
object to our processing of your Personal Information (including for direct marketing purposes); or
request your personal data be transferred to you or another data controller (the data portability right).

In addition, in certain circumstances we may process your personal data through automated decision-making, including profiling. This may include segmenting and tailoring the data to enable us to match our communication and products to your perceived needs. In the case we process your Personal Information through automated decision-making, we will inform you about the logic involved, as well as the significance and the envisaged consequences of such processing for you. Depending on your location, you may be able to request not to be subject to automated decision-making, including profiling.

If you would like to exercise these rights or understand if they apply to you, please click here to complete and submit an online request form. Alternatively, you can get in touch using the details set out at how to contact us below.

9. Complaints

Vestacy is committed to ensuring that privacy complaints are managed in an accountable, transparent, timely and meaningful way and in accordance with the APPs.

If you have a question, concern or complaint about this Privacy Policy or how we handle or process your personal information, please contact us using the details at how to contact us below.

We will then investigate using a process that is transparent and timely. We will also strive to identify and address systemic issues and continue to be open and accountable in our application of the Privacy Act 1988 (Cth).

If you are unhappy with the way we have handled your Personal Information or any privacy query or request that you have raised with us, you have a right to lodge a formal complaint with the Office of the Australian Information Commissioner by phone on 1300 363 992, email to enquiries@oaic.gov.au, online at https://www.oaic.gov.au/privacy/privacy-complaints/ or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW, 2001..

10. How long we retain your Personal Information

We will only retain your Personal Information as long as reasonably required for the purposes as set out in this Privacy Notice or otherwise to comply with legal or regulatory requirements applicable to us.

When your Personal Information is processed:

for the performance of your contract with us, we retain your Personal Information for a period of 7 years following completion of a contractual order;

for meeting, legal and regulatory requirements, we retain your Personal Information as it is set out by the applicable law; and

In all other cases, we process your Personal Information, depending on the type, for up to 2 years from the date of our last interaction with you.

11. Children

Most of our Sites are not directed towards children and we request that children below the age of 16 do not provide Personal Information through our Sites.

If you are the parent or legal guardian of a child under 16 who has registered on one of our Sites, or who you believe has otherwise provided Personal Information to us, please contact us using the details set out at how to contact us below to have the information deleted. Information voluntarily provided by children via e-mails, message boards, chat sessions etc. may be used by other parties to generate unsolicited e-mails. We encourage parents and legal guardians to inform children about how to use the Internet in a safe and responsible manner.

Depending on your location and where permitted by local law, we may collect information on your children in order to provide you with relevant information about our products and services.

12. Transfers to other countries

Your Personal Information may be transferred to and processed in other countries where laws governing the processing of Personal Information may be more or less stringent than the laws in your country (including jurisdictions outside the European Economic Area).

In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your Personal Information. Depending on the location of the Vestacy entity exporting the relevant Personal Information, this adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request.

To the extent required and valid under your local law, you consent to your Personal Information being transferred and processed this way.

13. How to contact us

We welcome your feedback. If you have any comments, questions or complaints regarding this Privacy Notice or our processing of your Personal Information, or would like to request access, correct or update your Personal Information, you can contact us by sending an e-mail to contact@vestacy.com or contacting us below:

Vestacy:

Schiphol Boulevard 267, 1118BH

Schiphol, the Netherlands

14. Changes to this Privacy Notice

This Privacy Notice was last modified on 15 February 2022. This document is a notice to you and not a contract between us. We may occasionally modify or amend it from time to time. When we make changes to this Privacy Notice, we will update the revision date at the top of this Privacy Notice. Where those changes are material, we will take steps to let you know such as providing you with prior notice of the pending update or posting a notice on our corporate website and/or social media pages. We encourage you to review this Privacy Notice whenever you visit our website. The new modified or amended Privacy Notice will apply from that revision date. Please always verify whether you have consulted the latest version of the Privacy Notice. Your continued use of our website constitutes your agreement to this Privacy Notice and any updates.