Introduction

Nutricia 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 S.A. and all its subsidiaries (“Danone”) collect and manage your personal data. It contains information on what 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 March 24th 2020.

 

Basic Principles And Our Privacy Commitment

At Danone we are 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;


• Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement

What Personal Data Do We Collect?

The personal data we collect varies depending upon 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:

• Personal contact data, such as your name, email address, physical address and telephone numbers;


• Account login details, such as your user ID, e-mail username and password. This is necessary to create a personal user account on one of our online communities;


• Communications with us, which may include details of our conversations via chat, care lines and/or customer service lines;


• Browser history, such as pages accessed, date of access, location when accessed. We do this to help enhance your online experience;


• Information related to your health;


• Information about people other than you, such as personal data about your family members, when you provide such information directly to us;


• Social media profiles;


• If ever you apply for employment with us, we will collect additional personal data, such as your employment history, educational history and employment references

We may also collect personal data about you indirectly when:

• You share content on social media pages, websites or applications related to our products or services or in response to our promotional material on social media

Why Do We Collect And Use Your Personal Data?

We collect your personal data so that 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:

• To process your payments, if you purchase our products or services, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;


• To send products, prescribed or otherwise requested;


• To process and answer your inquiries or to contact you in order to answer your questions and/or requests;


• To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;


• To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;


• For internal training and quality assurance purposes;


• To understand and assess the interests, wants, and changing needs of customers, in order to improving our website, our current products and services, and/or developing new products and services;


• To provide personalized communications to you as a customer

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 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.

Your Rights

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 should be aware that making these changes may affect the service that we can provide. However your rights will remain the same, if you wish to amend your changes at any time then you are free to do so via our contact page.

The right to access your personal data and correction

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.

The right to data portability

In the event whereby Nutricia are no longer contracted by the NHS/CCG to provide the Nutricia Homeward service then the data held can be transferred through your data portability rights to the new provider in accordance with Article 20 of the GDPR.

The right to deletion of your personal data

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

• your personal data is no longer necessary in relation to the purposes for which we collected it; or


• you withdraw any consent that you had previously given us to process your personal data, and there is no other legal ground to process that personal data; or


• you object to us processing your personal data for Danone’s legitimate interests (such as improving overall user experience on websites); or


• the personal data is not being processed lawfully; or


• your personal data needs to be deleted to comply with the law

If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal and NHS 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 de-identify it.

The right to restriction of processing

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

• you do not believe the personal data we have about you is accurate; or


• the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or


• 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


• 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 let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.

The right to object

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

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint directly with supervisory authority about how we process personal data.

How We Protect Your Personal Data

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.

Sharing Of Your 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:

Category of third parties:	Data type:	Purpose(s):
Healthcare Professions	Patient/carer details and required products	To ensure the patients are provided and delivered the correct products
CRM Platforms	Registration details for HCP and patients	For the management of online accounts and services
Pharmacies	Patient name, address, contact number and product information	For fulfilment of orders via prescription
Logistical Companies	Patient name, address, contact number and product information	For the delivery of required products
Email Platforms	Name, email address and product information	Only used in the rare occasion we need to recall a product
Patients/Carers	HCP work contact details	For resolution of queries, but only with HCPs consent
Analytical Agencies	Address, contact number, product information and survey satisfaction results, market research results	Monitor and improve service and product satisfaction levels

Automated Decision-Making And Profiling

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.

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 for further information on such processing.

Cookies And Other Technologies

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 promotions, or use our/third-party mobile applications and may include the following information:

• Information about your device browser and operating system;


• The IP address of the device you are using;


• Web pages of ours that you view;


• Links that you click while interactive with our services

Please see our cookie policy for more information on this.

How To Contact Us

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