Last Updated: 28 April 2021
This privacy notice (together with our Terms of Use) and any other documents referred to on it) (“Privacy Notice”) sets out how Glanbia plc and its affiliates (“Glanbia”, “we”, “us”) use personal information collected about you ("Personal Data") in the context of www.glanbia.com (the “Website”) and your dealings with us. Please read the following carefully to understand Glanbia’s views and practices regarding your Personal Data. For the purposes of this Privacy Notice, the controller of your Personal Data is Glanbia plc of Glanbia House, Kilkenny, Co. Kilkenny, R95E866.
Glanbia may amend its Privacy Notice from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes made by Glanbia.
1. What we collect
We may collect, use, store and transfer the following different kinds of Personal Data:
- Identity Data which may include your first name, last name and social media username.
- Contact Data which may include your address, email address, telephone numbers and postal code.
- Transaction Data which may include details about payments from you and details of products and services you have purchased from us.
- Competition Data which may include your response to the competition/promotion question, where this is an original answer and not multiple choice and any photos submitted as part of your entry.
- Technical Data which may include your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
- Communication and Usage Data which may include when you contact us by phone, letter or email or details on how you use our Website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data comes from your Personal Data but this type of data are processed to no longer directly or indirectly reveal your identity. As such, Aggregated Data are not considered Personal Data under law. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.
2. How your Personal Data is collected
We use different methods to collect Personal Data you including through:
- Direct interactions. You may give us your Identity, Contact, Profile, Transaction or Competition Data when you order services through the Website, enter a competition or promotion on the Website or by corresponding with us or contacting us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive Personal Data about you from third parties such as our customers and business partners. For example, we receive Technical Data from analytics providers such as Google Analytics.
3. What we do with the Personal Data we gather
This section details our purposes and legal bases for collecting and processing your Personal Data:
Purpose/Activity | Type of Personal Data | Lawful basis for Processing |
---|---|---|
To carry out our obligations under the Terms of Use or any other contracts entered into between you and us. | Identity Data Contact Data Transaction Data |
Performance of a contract with you. |
For internal record keeping purposes to support the delivery of our services. | Identity Data Contact Data Transaction Data Marketing and Communications Data | Necessary for our legitimate interests (to run our Website and to facilitate our services). |
To notify you about changes to our products or services that relate to your subscribed services. | Identity Data Contact Data | Necessary for our legitimate interests (to run our Website and to facilitate our services). |
To process and respond to any queries you submit to us. | Identity Data Contact Data Transaction Data Communication and Usage Data | Necessary for our legitimate interests (to run our Website and to facilitate our services). |
To enable you to participate in a promotion or competition run through the Website. | Identity Data Contact Data Transaction Data | Performance of a contract with you. |
To administer the promotion/ competition. | Identity Data Contact Data Competition Data Marketing and Communications | Performance of a contract with you. |
To publish the names of the winners on social media. | Identity Data | Necessary for our legitimate interests (to market our business and the promotion). |
To provide you with information and promotional material about products, special offers or other information which you request from us or we think you may find interesting. | Identity Data Contact Data Technical Data Usage Data Marketing and Communications Data | Your specific consent (to provide you with information about our products and services through direct marketing). Necessary for our legitimate interests (for example, where we are already in contact with you, we rely on our legitimate interest to continue to contact you about products which we think may be of interest to you.) |
To improve products and services directly related to the Website / supported services. | Technical Data | Necessary for our legitimate interests (to develop our products/services and grow our business). |
To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Identity Data Contact Data Technical Data | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). |
IMPORTANT: When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). |
4. Using your Personal Data for Marketing Purposes
As noted in the table above, we may also use your Personal Data, or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you. We will:
- obtain your consent to send direct marketing communications if you have opted in to receiving these communications as part of the sign up process, a Glanbia promotion / competition or through Website alerts.
- use our legitimate interests to contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale made by you.
IMPORTANT: If you do not want us to use your Personal Data in this way, please tick the relevant box situated on the form on which we collect your Personal Data for marketing purposes. If you have already signed up for marketing information, you can unsubscribe at any time by clicking the UNSUBSCRIBE button in your email. |
5. Security of your Personal Data
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect in accordance with data protection law.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your information transmitted to our Website; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to do our best to prevent unauthorised access.
6. Recipients of your Personal Data
We may share your Personal Data with:
Internal Third Parties: Glanbia group companies in Ireland and abroad (“Glanbia Group”) for our internal business purposes.
External Third Parties: We may share information with the following external third parties:
- Professional advisers including lawyers, bankers, financial service providers, auditors and insurers who provide banking, financial, legal, insurance and accounting services to us.
- IT and technical service providers which provide IT and technical services.
- Third party service providers such as payment service providers and customer relationship management service providers.
- Canvassing service providers and canvassing software service providers which provide the canvassing services and canvassing software.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
- The competition/promotion supplier for the purposes of administering the competition/promotion.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
7. International transfers
To deliver the services set out in this Privacy Notice to you, it is sometimes necessary for us to share your Personal Data with other members of Glanbia Group and service providers who are located outside the European Economic Area (“EEA”). We may transfer your Personal Data to another country outside the EEA if we are satisfied that the transfer complies with data protection law, appropriate safeguards and enforceable rights are in place.
The safeguard we use to facilitate these transfers is the European Commission’s Standard Contractual Clauses (“SCCs”). We either enter directly into SCCs with service providers, or require our service providers to have the SCCs in place with any non-EEA based sub-processors of such service providers who receive your Personal Data. Glanbia Group has in place internal SCCs.
8.Retention of your Personal Data
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Links to other Websites
Our Website may from time to time contain links to enable you to visit other websites of interest easily. However, once you follow a link to any of these websites, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any Personal Data which you provide whilst visiting such sites and such sites are not governed by our Privacy Notice. Please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. You should exercise caution and check these notices before you submit any personal information to these websites.
10. Your Data Protection Rights
You have rights under data protection law in relation to your Personal Data. You have the right to:
Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in certain scenarios.
Request the transfer of your Personal Data (as provided by you) to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You also have the right to make a complaint at any time to the Data Protection Commission (“DPC”), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
11. Contact Us
If you would like to exercise any of your data protection rights, or have any questions or concerns about how we use your Personal Data, please contact us at [email protected].