MILUPA PRIVACY POLICY

Milupa.ie knows that you care how your personal data is used and we recognize the importance of protecting your privacy.

This Privacy Statement explains how Danone Nutricia, Early Life Nutrition collects and manages your personal data. It contains information on the data we collect, how we use it, why we need it and how it can benefit you.

Contact us here if you have any queries and comments, or if you want to make a request regarding any of your data subject rights.

This privacy statement was last updated on April 16th, 2018.

Danone Nutricia Early Life Nutrition is committed to protecting your right to privacy. We aim to protect any personal data we hold, to manage your personal data in a responsible way and to be transparent in our practices. Your trust is important to us. We have therefore committed ourselves to the following basic principles:

• You have no obligation to provide any personal data requested by us. However, if you choose not to, we may not be able to provide you with some services or products
• We only collect and process your data for the purposes set out in this Privacy Statement or for specific purposes that we share with you and/or that you have consented to
• We aim to collect, process and use as little personal data as possible;
• When we do collect your personal data, we aim to keep it as accurate and up to date as possible
• If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it at the earliest opportunity
• Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement

The personal data we collect varies depending on the purpose of the collection and the product or service we are providing you.

Generally, we may collect the following types of personal data from you directly:

1. Details of communications with us, which may include details of our conversations via the Careline (phone, email, Live Chat or web forms) or direct message from social media pages.
2. Browser histories, such as pages accessed, date of access, location when accessed, and IP address;
3. Social media profiles;

We may also collect personal data about you indirectly when:

1. you share content on social media pages, websites or applications related to our website or in response to our promotional material on social media; or
2. we may collect personal data about you from information collected by other websites (for instance, we may place an ad on a third party website, and when you click on that ad, we may receive information about you and other website visitors in order to measure the reach and success of that ad).

We collect your personal data so we can provide you with the best online experience and to provide you with a high quality of customer service. In particular, we may collect, hold, use and disclose your personal data for the following purposes:

1. To process and answer your enquiries, complaints or to contact you in order to answer your questions
2. To develop and improve our products, services, communication methods and the functionality of our websites
3. To manage our everyday business needs in connection with your participation in competitions or promotional activities
4. To authenticate your identity when contacting us by telephone, electronic means or otherwise
5. For internal training and quality assurance purposes
6. To understand and assess your interests wants, and changing needs in order to improve our website, our current products, and services, and/or developing new products and services
7. To provide personalized products and communications as well as product recommendations

We may also need your personal data to comply with legal obligations or in the context of a contractual relationship that we have with you.

When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.

Where appropriate, we will always ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time. You can do so by contacting us through any of our usual channels.

Where we process your personal data, you are entitled to a number of rights and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can change your preferences any time by contacting us.

You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us here.

Your personal data is portable. This means it can be moved, copied or transmitted electronically. However, this right only applies where:

1. a) The processing is based on your consent;
2. b) The processing takes place for the performance of a contract;
3. c) The processing takes place by automated means;

If you wish to exercise your right to data portability, please contact us here.

You have right to request that we delete your data if:

1. you do not believe the personal data we have about you is accurate;
2. the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or
3. we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or
4. you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to delete the personal data we hold about you, you can contact us here office hours.  We will take reasonable steps to respond to your request in accordance with legal requirements.

If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently anonymise it.

You have the right to restrict the processing of your personal data if

1. you do not believe the personal data we have about you is accurate; or
2. the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or
3. we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or
4. you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to restrict our processing of your personal data, please contact us here and we will take reasonable steps to respond to your request in accordance with legal requirements.

You have the right to object to the processing of your personal data at any time. Please contact us here.

You have the right to lodge a complaint directly with the Irish Data Protection Commissioner about how we process personal data. You can find out more about this process at www.dataprotection.ie

We understand that the security of your personal data is important. We make our best efforts to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure. We have implemented a number of security measures to help protect your personal data. For example, we implement access controls, use firewalls, and secure servers, and we encrypt personal data.

When we share your personal data with affiliates and other organizations, we make sure we only do so with organizations that safeguard and protect your personal data and comply with applicable privacy laws in the same or similar way that we do.

Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement. We may, however, share your data when required by law and/or government authorities.

Your personal data will be shared with the following third parties for the purposes described:

Personal data may be processed outside the European Economic Area (EEA). When processed outside the EEA, Danone will make sure that this cross-border data processing is protected by adequate safeguards.

The safeguards that we use to protect cross-border data processing include:

1. Model Contractual Clauses approved by European Commission. These standardized contractual clauses provide sufficient safeguards to meet the adequacy and security requirements of the European General Data Protection Regulation;
2. Certifications which demonstrate that third parties outside of the EEA process personal data in a way that is consistent with the European General Data Protection Regulation. These certifications are approved either by the European Commission, a competent supervisory authority or a competent national accreditation body in terms of General Data Protection Regulation.

Your personal data is not currently transferred to any countries internationally. This section will be updated if it ever is likely to be transferred.

For some services and products, we may process your personal data using automated means. Essentially this means that decisions are taken automatically without human intervention.  An example would be in the event of a notified baby death, your details would be checked for a duplicate account under our other databases and automatically unsubscribed. Only in circumstances where accounts are registered with the same email address, can this process be enacted.

We may also process your personal data for profiling purposes to predict your behaviour on our website or products that may be of interest to you.

If we intend to make use of such methods, we will, of course, inform you and we will give you an opportunity to object to these processes in advance. You are also free to contact us here for further information on such processing.

We may also collect personal data about you through the use of cookies and other technologies. This may occur when you visit our sites or third-party sites, view our online content, or use our/third-party mobile applications and may include the following information:

a) Information about your device browser and operating system;
b) The IP address of the device you are using;
c) Web pages of ours that you view;
d) Links that you click while interacting with our services.

Please see our cookie statement for more information on this.

If you have any questions, comments or complaints regarding this Privacy Statement or the processing of your personal data, please contact us here.

If you wish to restrict our processing of your personal data, please contact us here and we will take reasonable steps to respond to your request in accordance with legal requirements.