Ferrero Asia Pacific Pte. Ltd. ("Ferrero") is committed to protecting the privacy of users of this website (the "Website") and will do everything in its power to ensure that users' Personal Data (as defined below) is treated with respect to their fundamental rights and freedoms as well as personal dignity, with particular reference to confidentiality.
In general, any information and Personal Data which you provide, or which is otherwise gathered by us in the context of the Website, will be used by Ferrero in compliance with the applicable legislation (e.g., Singapore’s Personal Data Protection Act (“PDPA”), EU’s General Data Protection Rules, etc.).
The Data Controller/Owner that oversees all Personal Data Processing operations carried out through the Website is Ferrero, with registered offices at 80 Robinson Road #02-00 Singapore 068898. Ferrero has appointed a local coordinator for privacy. To get in touch with the local coordinator for any information regarding the processing of Personal Data by Ferrero, including a list of Ferrero’s data processors/ intermediaries, please contact: firstname.lastname@example.org.
WHAT INFORMATION DO WE COLLECT FROM YOU?
As you use the Website and, in particular, as you provide information and upload files to the Website in order to access the Website's services, Ferrero may Process information related to you as an individual and which allows you to be identified, either directly or together with additional information ("Personal Data"). This Personal Data can be Processed by Ferrero both when you choose to provide it (e.g., when you request any services provided by Ferrero over the Website) or simply by analyzing your behaviour on the Website.
By your voluntary submission of your Personal Data to us, you consent to the Processing of your Personal Data by Ferrero and/or its data processors/ intermediaries for the purposes as set out under “BROWSING DATA” and “WHY DO WE PROCESS THIS INFORMATION? PURPOSES OF PROCESSING AND LEGAL GROUNDS” as applicable.
In this regard, you should ensure that all Personal Data submitted to us is complete, accurate and true at the time of submission. Failure on your part to do so may result in our inability to provide you with services you have requested.
DATA VOLUNTARILY PROVIDED BY USERS
When creating an account on the Website, you will be asked to provide certain Personal Data such as contact details (e.g. your name, email address, telephone number, country of residence and physical address) and marketing preferences, for the purposes listed below.
Where the Website allows you to register through your personal profile in social media (Social Login) with your prior and revocable consent, we may access the same limited information included in such profile, related to your name, age, location, likes, interests, contacts and images.
You may, on providing Ferrero with reasonable notice, at any time withdraw any consent given in respect of the Processing of your Personal Data for any purpose. Users shall not be required to provide Personal Data to browse public pages of the Website.
The Website's operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website's users as part of their routine operation (“Information”). The transmission of such Information to Ferrero and/or its data processors/ intermediaries is automatic when using Internet communication protocols. Although Ferrero does not Process this Information in order to associate it to specific users, it is still possible that, by their nature and through Processing and association with further data held by third parties, such Information may permit the identification of specific users, either directly via that Information or from that Information and other information to which Ferrero has or is likely to have access. As such, this Information must also be considered Personal Data, although the purposes for which such Information shall be Processed shall be limited to those purposes set out below in this section, “BROWSING DATA”).
This Information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, information about your activities on our Website (for instance, the pages you visit, the goods you view), the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), details on the device (for instance, your computer, tablet or smartphone) which you use to access our Website and so on, by means of cookies and other technologies which allow this tracking.
Such Information shall only be used by Ferrero for anonymous, statistical purposes about the use of the Website, without associating them to any identifier of the users, to ensure the Website’s correct operation and identify any faults and/or abuse of the Website. This Information may also be used for the purposes of investigating liabilities in the event of information crimes committed against Ferrero in relation to the Website.
The Processing of Personal Data shall be made by such procedures, technical and electronic means, which are suitable to protect the confidentiality and security of Personal Data and shall involve activities such as collection, recording, organization, storage, consultation, elaboration, alteration, selection, retrieval, alignment, use, combination, block, communication, dissemination, erasure, and destruction of data, including a combination of two or more of such activities.
WHY DO WE PROCESS THIS INFORMATION? PURPOSES OF PROCESSING AND LEGAL GROUNDS
Ferrero intends to use your Personal Data for the following purposes:
- To provide answers or services you request, including allowing the creation of an account, to receive information from Ferrero and sending you alerts by means of push notifications; to verify your identity and assist you, in case you lose or forget your login/password details for any of Ferrero's registration services; to allow you to create and maintain a registered user profile, to process transactions and enrolments you request, including emails; to send you newsletters you have subscribed to as a service (containing only informative content); and to provide any other services which you may request (“Service Provision”). If you choose not to provide (or if you withdraw) your consent to the Processing of your Personal Data for the purpose of Service Provision, Ferrero will not be able to provide any services to you.
- For marketing, promotional and publicity purposes, including to carry out direct marketing, as well as to carry out studies, research, market statistics or surveys, via e-mail, SMS, push notifications, pop-up banners, instant messaging, phone calls by an operator, Ferrero's official social media pages, regarding Ferrero's products and services ("Marketing") and to send you offers, promotions or other information about our goods and services Processing for these purposes is based on your consent. It is never mandatory for you to give consent to Ferrero for the use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to provide (or if you withdraw) your consent to the Processing of your Personal Data for Marketing purposes (aside from not being able to receive further marketing communications from Ferrero). Your Personal Data will only be Processed for Marketing purposes in accordance with applicable laws, including the Do Not Call provisions of the PDPA.
- For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services provided by Ferrero which are identical or similar to those you have previously requested through the use of the Website ("Soft Spam"). You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from Ferrero), by objecting through the unsubscribe link provided at the bottom of all such communications.
- To create your user profile (individual and/or aggregate profiles) on our Website, by collecting and analyzing information on the preferences you select and choices you make on the Website as well as on your general activities on the Website, through the use of profiling cookies ("Profiling"). This information will be used to personalize the Service Provision by Ferrero, where possible, to suit your preferences and choices, as well as to serve you with information and advertisements which may be relevant to you and your interests, to propose customized offers that may be of your interest, to give you information about other websites/services which Ferrero believes you may be interested in. All algorithms involved in this processing are regularly tested, to ensure the processing's fairness and control for bias. Processing for this purpose is based on your consent, collected by means of the cookie pop-up banner and/or a specific tick box. It is never mandatory for you to give consent to Ferrero for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to provide (or if you withdraw) your consent to the Processing of your Personal Data for Profiling purposes (aside from not being able to benefit from greater personalization of your user experience regarding the Website). Any consent given may be withdrawn at a later stage, either by modifying your device settings or contacting Ferrero’s local privacy coordinator at the email address mentioned above.
- If applicable, for compliance with any written laws which impose upon Ferrero a requirement for the collection and/or further processing of certain kinds of Personal Data, including regulations on contests in case users participate to contests or prizes ("Compliance"). When you provide any Personal Data to Ferrero, Ferrero must process it in accordance with the applicable laws, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations. Ferrero may carry out such collection, use, disclosure and/or any other processing of Personal Data obtained without the individual’s consent only if necessary (i) to perform, or take steps with view to enter into, a contract with the individual concerned, (ii) to comply with legal obligations of Ferrero (iii) to protect the vital interests of the individual concerned in a `life or death' situation; or (iv) as permitted by “other exemptions” under PDPA (as specified in Second, Third, Fourth, Fifth and Sixth Schedule of PDPA) and any other laws. No consent is required for the Processing of Personal Data for the purposes of Compliance since such Processing is necessary or authorised under written law.
- To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website ("Misuse/Fraud"). Processing for this purpose is necessary to pursue Ferrero's legitimate interests in preventing and detecting fraudulent activities or misuse of the Website (for potentially criminal purposes).
- To analyze and improve our service provision, enhance the Website, evaluate the effectiveness of Ferrero's marketing activities and services, perform statistical and demographics analyses on Ferrero's corporate clients and registered users ("Analytics"). Processing for this purpose is necessary to pursue Ferrero's legitimate interests in the development and administration of the Website and to improve the services provided by Ferrero.
- Your voluntary submission of the Personal Data for job application purposes also reflects your consent to the sharing of this information for the purposes of recruitment, assessment and evaluation purposes. If you are an authorised representative of any third-party, you also confirm that you have obtained the relevant voluntary consents from such third parties for us to collect, process, utilise and disclose their personal data.
WHO WILL BE ABLE TO ACCESS YOUR PERSONAL DATA?
- Other companies within the Ferrero Group for internal administrative purposes;
- Duly appointed data processors/intermediaries, providing specific Processing or accessory services (e.g. storing data, sending out messages for us, web hosting, contests' management, consumer service, IT services regarding the Website operation, emailing) on Ferrero's behalf and under its instructions, whose data protection maturity has been checked by Ferrero before entering into the required data processing agreement. The full updated list of appointed as data processors/intermediaries, which may include other companies within the Ferrero Group, is available from our data protection officer, who is contactable at email address: email@example.com;
- Selected individuals authorized by Ferrero to Process Personal Data needed to carry out activities strictly related to the provision of the services (e.g. technical maintenance of network equipment and electronic communications networks), who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Ferrero);
- Public entities, bodies or authorities in accordance with the applicable law or binding orders of those entities, bodies or authorities. We may also disclose your Personal Data when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud, or respond to a government request.
Personal data shall not be disclosed nor transferred to third parties (save for those set out above), except in the event of extraordinary corporate transactions, when Personal Data may be assigned or contributed to third party purchasers/lessees or assigns in accordance with applicable laws.
Ferrero will not transfer Personal Data outside Singapore unless, prior to the transfer, Ferrero takes appropriate steps to ensure that the recipient of the Personal Data is bound by legally enforceable obligations to provide the transferred Personal Data a level of protection which is comparable to the protection under the PDPA or any other data protection regulation, or Ferrero has obtained your explicit consent to the transfer.
Personal Data may be transferred to other countries where the premises or the servers of Ferrero or of any of its suppliers are located, provided that prior to the transfer, Ferrero takes appropriate steps to ensure that an adequate level of data protection is guaranteed.
In order to comply with laws protecting children's online privacy, Ferrero does not knowingly collect any Personal Data from children under 16. Ferrero takes children's privacy seriously. As such, we would recommend that a parent or guardian assist and guide any children under 16 who may intend to browse the Website or access the services provided by Ferrero. Children under age 16 should not use Ferrero’s Website or services without the supervision of a parent or guardian. In the event that Ferrero learns that it has inadvertently collected Personal Data from a child under the age of 16, Ferrero will promptly delete such information.
SECURITY OF PERSONAL DATA
Personal Data Processed by Ferrero may be stored on servers in Singapore, the European Union and on cloud servers owned by data processors/intermediaries e.g. third party cloud service providers. Ferrero shall protect all Personal Data in its possession or under its control by making reasonable security arrangements to prevent destruction, loss (including accidental loss) of any storage medium or device on which Personal Data is stored, unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, or use that is incompatible with the initial purpose of collection. A detailed list of Ferrero’s technical and organizational security measures is available here.
Although every reasonable effort has been made to ensure that all Personal Data will be protected, to the extent permitted by applicable laws, Ferrero shall not be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
RETENTION OF PERSONAL DATA
Generally, Ferrero will keep your Personal Data only for as long as strictly necessary, according to the purpose for which it was collected:
- Personal Data Processed for Service Provision will be kept by Ferrero for the period deemed strictly necessary to fulfil such purposes. Information will, however, be kept for longer if we need it to address any claims regarding the services or for legal purposes e.g for any legal action involving Ferrero in relation to the Processing of the Personal Data (“Legal Purposes”).
- Personal Data Processed for Marketing and Profiling will be kept by Ferrero from the moment you give consent until your consent is withdrawn. Where your consent has not been withdrawn, Ferrero will ask for your consent to be renewed at fixed intervals of 24 months. Once consent is withdrawn (or not given, following a renewal request), Personal Data will no longer be used for these purposes, although it may still be kept by Ferrero for Legal Purposes.
- Personal Data Processed for promotions involving consumers (“Consumer Promotions”) will be kept by Ferrero from the moment it is provided by you until 6 months after the end of the relevant Consumer Promotion or until consent is withdrawn. Information will, however, be kept longer if Ferrero needs it to address any claims regarding the Consumer Promotion or for Legal Purposes.
- Personal Data Processed for Research purposes will be kept by Ferrero for 5 years.
- Personal Data Processed for Soft Spam will be kept by Ferrero from the moment where it is provided by you to Ferrero until you object to this Processing through the unsubscribe link provided at the bottom of all such communications. Once you have objected, Personal Data will no longer be used for these purposes, although it may still be kept by Ferrero, as may be necessary for Legal Purposes.
- Personal Data Processed for Compliance will be kept by Ferrero for the period required by the specific legal obligations for which the Personal Data was Processed.
- Personal Data Processed for preventing Misuse/Fraud and Analytics will be kept by Ferrero for as long as deemed strictly necessary to fulfil the purposes for which it was Processed.
After such periods, all Personal Data shall be deleted or anonymized, except such Personal Data that we are required by law to keep for a longer period.
WHAT ARE YOUR RIGHTS? HOW CAN YOU EXERCISE THEM?
As a data subject, you are entitled to exercise the following rights, at any time:
- Obtain confirmation as to the existence of your Personal Data being Processed by Ferrero, access and obtain copy of such data;
- Update, modify and/or rectify your Personal Data where it may be inaccurate or incomplete;
- Obtain information about the ways in which your Personal Data has been or may have been used or disclosed by Ferrero or its data intermediaries within a year before the date of your request;
- Withdraw your consent to the Processing of your Personal Data by giving reasonable written notice to Ferrero;
Please note that most of the Personal Data you provide to Ferrero can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the Website.
When requesting services via the Website, you may have selected one or more means of communication via which Personal Data Processing for Marketing purposes may be carried out (e.g., phone, SMS, email, mail, social media). You may withdraw your consent to this Processing for all selected means of communication, or you can choose to block specific means only (e.g., if you only withdraw consent for SMS marketing communications, you will not receive further communications via SMS, but may continue to receive them via e-mail), by means of your user profile created on the Website, where applicable. You can also withdraw consent for Marketing (for communications received via e-mail) by selecting the appropriate link included at the bottom of every marketing message.
Consent for Profiling carried out by cookies may be withdrawn at any time. Where consent for Profiling was given via a specific tick box, you may withdraw this consent by changing your preferences, at any time, within your user profile created on the Website, where applicable.
At any time, you shall be entitled to exercise the rights established by the law in force, by addressing the relevant request to our Privacy Department at email address: firstname.lastname@example.org.