Privacy Policy

1. APPLICATION OF THIS PRIVACY POLICY
   1. This Privacy Policy (“Policy”) forms part of the Terms of Use (“Terms”) relating to the use of the Beiersdorf “Beiersdorf Precision Marketing Academy Platform” (the “Platform”).
   2. Beiersdorf Near East FZ-LLC (” Beiersdorf” “we” “us” or “our”) is committed to safeguarding the privacy of the personal information that is provided to us or collected by us during the course of our business as well as the personal information we receive from you (“User”, “you” or “your”) through the Platform. This Policy, describes how and why we collect, store and use personal information, and provides information about your rights. Pleaseread the following information carefully to understand our views and practices regarding how we handle personal information. 
       
2. COLLECTION OF PERSONAL INFORMATION
   1. By using the Platform, you consent to our collection, use and disclosure of your personal information in accordance with the terms of this Policy. You may withdraw such consent at any time, however this will not affect the lawfulness of the processing based on your consent prior to the withdrawal, or where we have other legitimate reasons for processing your personal data.
   2. We may collect and process the following personal information:
      
      Information you give us:
      - If you are enquiring or, conducting any transactions, using the Platform, then we may request and process with your consent your personal information including your name, e-mail address, telephone number, address and date of birth;
      - You may give us information about you when by registering on our Platform or by corresponding with us by phone, e-mail or other electronic means, or in writing, as well as other information you provide directly to us, including in conversation with our employees and staff. 
      
      Information we collect about you: 
      With regard to each of your visits to our Platform, we may automatically collect the following information:
      - technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system; and
      - information about your visit; services you viewed or searched for; page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs). 
      
      Information we receive from other sources:
      We may also receive information about you from other sources such as our local authorized business partners and service providers. 
       
3. PURPOSES
   1. We use your personal information for the following purposes where permitted by applicable law:
      - Where you give us consent, carrying out business development (including sending information about promotions and details of events;
      - Where it is in our, or a third party’s legitimate interests. These interests include:
            > auditing usage of the Platform;
            > processing and responding to inquiries, and providing our products; and
            > administering promotions and events where you take part;
      - Where required by law, such as by:
           > responding to requests from government or law enforcement authorities conducting an investigation; and
          > complying with any applicable legislation.
       
4. SHARING YOUR PERSONAL INFORMATION
   1. We may also share your personal information with third parties including certain service providers we have retained in connection with our business activity.
   2. Moreover, we may disclose your personal information to third parties:
      - if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
      - if Beiersdorf, its business, or its assets are acquired by a third party, in which case personal information held by it about its Users, suppliers, or customers will be one of the transferred assets;
      - in order to enforce or apply our terms and conditions and other agreements; or
      - to protect the rights, property, or safety of Beiersdorf, our Users, our customers, or others.
   3. We may also disclose your personal information to competent administrative, judicial, and/or law enforcement authorities or other government officials, if we are required to disclose or share your personal information in order to prevent crime (including any operation related to anti-money laundering or counter-terrorism financing), detect fraud, comply with any legal obligation or if we are required to do so by a legal process.
       
5. AUTOMATICALLY RECORDED INFORMATION (NON-PERSONAL DATA)
   1. When you access the Platform, we automatically collect general information that is not related to your person, e.g. the name of the internet service provider (or with company networks, the name of your firm), information on the Platform you called up, date and time of the call up and the operating system and browser version in use.
   2. This information is collected and analyzed in anonymized form. It is used solely for the purpose of improving the attractiveness, content and functionality of our Platform. It is not processed any further nor is it transmitted to third parties.
       
6. COOKIES AND INTERNET ADVERTISING
   1. We may use ‘cookies’ to improve the Platform. Cookies are small files that are sent to a computer's hard drive by a web server. Cookies enable websites to remember who you are. Information from cookies may include information relating to your use of the Platform, information about your computer (such as IP address and browser type), and demographic data. Most internet browsers have a mechanism notifying you when you receive a new cookie and showing you how to reject new cookies or disable cookies altogether.
       
7. SECURITY
   We use up to date information storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorized access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. Whilst we have put in place physical, electronic and managerial procedures to secure and safeguard your personal information, we will not be held responsible for any unauthorised access by third parties and we cannot guarantee that the personal information provided by you or that is transmitted via the Platform or by e-mail is totally secure and safe and you provide it at your own risk.
    
8. CROSS-BORDER TRANSFERS
   Your personal information may be transferred to and stored in servers and facilities located in your region or another country.  Some of these countries may not provide the same level of data protection as the UAE.  
   
   When we transfer your information to other countries, we will use, share and safeguard that information as described in this Policy. To operate the Platform or to manage your participation in promotions and events, we may transfer the personal information we collect from or about you to countries which may not provide the same level of data protection as the UAE. 
    
9. MARKETING COMMUNICATIONS
   1. We, or trusted third parties on our behalf, may contact you by email or post with information about our products or promotions that might be of interest to you. Where necessary, at the time that you provide your personal information to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal information in order to tell you about such products, services and promotions.
   2. Withdrawal of consent to receive marketing communications will not affect the processing of personal information in connection with the operation of the Platform. You may, at any time, withdraw your consent to receive commercial marketing communications by clicking on the link provided in the relevant email, or by emailing us on reka.halasi@beiersdorf.com
       
10. REQUESTS
    1. You may request us to provide a copy of the personal information we hold about you, and to have personal information removed or any inaccurate personal information about you corrected.
    2. If you would like your personal information to be removed from our records or if your personal information requires amending then we will endeavor to correct, update or remove your personal information as swiftly as possible. You can make such request by emailing us on reka.halasi@beiersdorf.com or by post to: P.O Box 502350, Dubai, UAE.
        
11. RETENTION
    1. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by applicable law.
    2. Your personal information that is processed for marketing purposes will be stored until you exercise the right to withdraw consent, and once such right is exercised, your personal information will be kept only during the applicable statute of limitations period for any disputes or liabilities that may arise as a consequence of the processing of that information (which is up to 15 years in the UAE). Once potential actions are time barred we will proceed to delete the personal data. In any other circumstances, we will only retain your personal information for a shorter or longer period as required by any applicable law.
        
12. LINKS TO THIRD PARTY SITES
    The Platform may contain links to other unaffiliated third party websites.  Please note that Beiersdorf is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites.  You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal information.
     
13. CHANGES TO THIS PRIVACY POLICY
    We may from time to time make changes to this Policy. Please check back regularly to keep informed of updates to this Policy. These changes are effective immediately, after they are posted on the Platform.
     
14. CONTACT DETAILS
    If you have any questions about this Policy, or our processing of your personal data, please contact us onreka.halasi@beiersdorf.com