Company Privacy Notice

Last Updated November 2022

Privacy Principles | Purpose and Reach | Information Collected, Legal Bases & Disclosures | Marketing, Cookies & Websites | Notice on Cookies | Children’s Data, Service Providers & Other Information | Your Rights | International Transfers of Personal Data

 

Who We Are

Reckitt values your privacy and the protection of your Personal Data. This Company Privacy Notice (“Notice”) explains how we collect, store, use, share, transfer, delete, disclose, and process information collected from or about you (“Personal Data”) by Company and any directly or indirectly controlled affiliate or subsidiary thereof (collectively, “Company,” “we,” “our,” or “us”). As an international company, Company has multiple legal entities in different jurisdictions that are responsible for the Personal Data they process, and we process Personal Data in accordance with these applicable laws and regulations. Learn more about Reckitt and its brands.

Company’s Privacy Principles

Across all of our business activities we seek to base our privacy practices on accepted principles of privacy and data protection. These principles include:

• Transparent: To be open about privacy practices, policies, developments, and the details of any processing that takes place and to specify the purposes for which Personal Data is collected and processed before such collection takes place.
  
  
• Fair in Processing: To obtain Personal Data in good faith by legitimate, lawful, and fair means and to process Personal Data only in accordance with the purposes for which it was collected.
  
  
• Engage in Privacy by Design: To ensure we create solutions and process data with privacy at the forefront and in accordance with these principles.
  
  
• Accountable: To be accountable for complying with measures that give effect to these principles, including by ensuring accountability of third parties with whom we interact through appropriate contracts.
  
  
• Responsive to Privacy Requests: To be responsive to individual’s privacy rights afforded by law.
  
  
• Protective: To protect Personal Data using reasonable security safeguards, to ensure data accuracy, and to limit use to that which is necessary for the processing purpose.

The Purpose and Reach of this Privacy Notice

This Notice describes the types of Personal Data that Company may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data.

This Notice applies to Personal Data collected or processed by us online (through websites, applications, email, and otherwise) (“Online Services”); and in other situations where you interact with us, including but not limited to interacting with or visiting our sites and offices or our events (e.g., tradeshows and conferences) (such products, services, Online Services, and other systems collectively, the “Products and Services”); when we process your data as an employee of a company for which we provide Products or Services; or anywhere this Notice is posted or referenced. This Notice also applies to Personal Data that is collected or processed when you interact with us in person, by telephone, or by mail.

• Company may have other unique privacy notices that apply to certain specific situations and in such instances, the unique privacy notices control.
• If you provide us with Personal Data of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Company (including obtaining consent, if required).
• Please review this Notice carefully. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice.
• The Company subsidiary or affiliate with whom you are interacting or who owns and operates the Product or Service is, where applicable, the entity responsible for the collection and use of your Personal Data.

Information Collected

What is Personal Data?

• “Personal Data” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link directly to an individual, such as name, address, email address, telephone number, or credit card number, as applicable.
• In limited circumstances, Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, medical and health information, financial account information, geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, and other information.
• We will process any Personal Data we collect in accordance with applicable law and as described in this Notice (unless, as explained above, a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Data, certain offerings may be unavailable to you.

Below is a high-level summary of the types of Personal Data we may collect from you.  Following that high-level summary is additional detail and information on how we collect, process, and use Personal Data and the potential recipients of your Personal Data, and how we have done so in the preceding 12 months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which are included below, but please note that not all jurisdictions may recognize all legal bases.

 

 

Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Inquiries
We may process your Personal Data when you: (1) visit our websites and our physical locations; (2) submit inquiries to us both online (e.g., via email) or offline (e.g., by written letters); (3) sign up for our newsletters or other informational or marketing materials; and/or (4) register for, visit, or use our online Products and Services.
Examples of the types of data we process
Identity and contact information, such as:	• first and last name • email address • postal address • phone number • username and password
Other personal information, such as:	• age • gender • date of birth
Visual and audio information, such as:	• still images • video (including via CCTV) • recordings of your calls with our customer service representatives
Technical Information, such as:	• Internet Protocol (IP) addresses (which may identify your general geographic location or company) • browser type and browser language • device type • advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) • date and time you use our Products and Services • Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services • activity on our Products and Services and referring websites or applications • data collected from cookies or other similar technologies • geolocation information
Anonymized / Deidentified Data:	• Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws
Where do we get the data?
• you directly • your devices • our security systems (including CCTV) • third parties
Why we process the data?
• to provide you with our Products and Services • to communicate with you (about your inquiry) • to administer our relationship with your organization • to send you updates • to identify and authenticate you • to customize content for you • to detect security incidents • to protect against malicious or illegal activity • to ensure the appropriate use of our Products and Services • to improve our Products and Services • for short-term, transient use • for administrative purposes • for marketing, internal research, and development • for quality assurance and to assist in training and development of our representatives
The legal bases for processing:
• for the purposes of our legitimate interests • in preparation for or to perform a contract with you • in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law
Who receives the data?
• Company, our affiliates, subsidiaries, and related companies • partners that assist us in providing the Products or Services or help us improve our marketing or administration

 

Employment and Candidates
We may process your Personal Data when you apply or are a candidate for employment or apprenticeship at Company.
Examples of the types of data we process
Identity and contact information, such as:	• first and last name • company/employer • email address • postal address • phone number • username and password
Other personal information, such as:	• age • gender • marital status • disability • date of birth
Technical Information, such as:	• Internet Protocol (IP) addresses (which may identify your general geographic location or company) • browser type and browser language • device type • advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) • date and time you use our Products and Services • Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services • activity on our Products and Services and referring websites or applications • data collected from cookies or other similar technologies • geolocation information
Professional and educational information, such as:	• job title or position • employer • work skills • employment history • graduate degrees • certifications • specialized training • responses to surveys and questionnaires
Anonymized / Deidentified Data:	• Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws
Where do we get the data?
• you directly • your employer or principal • your devices • our business partners and other third parties
Why we process the data?
• to communicate with you • to identify and authenticate you • to detect security incidents • to protect against malicious or illegal activity • for short-term, transient use • for administrative purposes • for marketing, internal research, and development
The legal bases for processing:
• for the purposes of our legitimate interests • in preparation for or to perform a contract • to comply with a legal obligation • in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law
Who receives the data?
• Company, our affiliates, subsidiaries, and related companies • partners that assist us in providing the Products or Services or help us improve our marketing or administration

 

Business Partners and Their Employees, Agents, and Contractors
We may process your Personal Data if you are an employee, agent, or contractor of a third party with whom Company does business, hires as a service provider, or otherwise partners with.
Examples of the types of data we process
Identity and contact information, such as:	• first and last name • company/employer • email address • postal address • phone number • username and password
Other personal information, such as:	• age • gender • disability • date of birth
Technical Information, such as:	• Internet Protocol (IP) addresses (which may identify your general geographic location or company) • browser type and browser language • device type • advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) • date and time you use our Products and Services • Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services • activity on our Products and Services and referring websites or applications • data collected from cookies or other similar technologies • geolocation information
Commercial and financial information, such as:	• Products and Services purchased, obtained, or considered • request documentation • customer service records • financial transaction history • financial account number
Anonymized / Deidentified Data:	• Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws
Where do we get the data?
• you directly • our business partners and other third parties • your employer or principal • your devices
Why we process the data?
• to communicate with you (about your inquiry) • to administer our relationship with your organization • to send you updates • to identify and authenticate you • to detect security incidents • to protect against malicious or illegal activity • for short-term, transient use • for administrative purposes • for marketing, internal research, and development • to provide you with our Products and Services • to communicate with you • to identify and authenticate you
The legal bases for processing:
• for the purposes of our legitimate interests • for medical diagnosis and the provision of healthcare and treatment • in the public interest • to comply with a legal obligation • in preparation for or to perform a contract • to protect vital interests • to ensure high standards of quality and safety of healthcare and medical devices • in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law
Who receives the data?
• Company, our affiliates, subsidiaries, and related companies • our customers • partners that assist us in providing the Products or Services or help us improve our marketing or administration

 

Children

Company does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 without the permission of such minor’s parents or legal guardians.

Marketing, Cookies, and Tracking

Marketing Uses, Cookies, and Other Activities 

To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we may engage in the following activities:

• We may use your contact details to contact you to determine whether you would like to initiate a business relationship with us or to send you marketing emails. If you do not wish to receive such marketing emails, you may opt out by declining to receive such emails when registering or in our subsequent communications by following opt-out instructions included in the email or at other information collection points on the Online Services.
• We may display advertisements to you regarding Products and Services that we believe are relevant to you based on your activities on the Online Services or on other web or digital properties. Such advertisements may be shown on our Online Services or the online services of others. We achieve this by using, and allowing third parties (e.g., Facebook, LinkedIn) to use certain cookies, eTags, pixels, web beacons, and other tracking technologies to track your activities on our Online Services and other online services. For more information about these activities and how to manage or opt out of them, please see our Notice on Cookies.
• We may make customer offers to you based on your activities across different Online Services, including activities on other web or digital properties or your other interactions with Company that are not via the Online Services (e.g., regional offers based on the location of your office listed on order forms).
• We also perform statistical analyses of the users of our Online Services to improve the functionality, content, design, and navigation of the Online Services.

Processing Using Website Tracking

On certain of our websites, we use Google Analytics, to help us understand how users engage with this and other of our websites. Google Analytics may track your activity on our sites (i.e., the pages you have seen and the links you have clicked on) and helps us measure how you interact with the content that we provide. This information is used to compile reports and to help us improve the sites. The reports we receive disclose website trends without identifying individual visitors. Learn more about Google’s privacy practices, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, or as described in our Notice on Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. We will honor such ‘Do-Not-Track’ requests. 

Interactive Features of our Websites

To the extent we offer any public or group forums on our Products or Services, such as newsfeeds, blogs, message boards, or similar tools (“Interactive Features”), the posts or comments you make may be public and viewed by others. You should use care before posting information about yourself, including Personal Data. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to Interactive Features over the Products and Services. Except when required to do so by applicable law, we assume no obligation to remove Personal Data you post on our Products and Services, and your disclosure of any Personal Data through the Interactive Features is at your own risk.

 

Notice on Cookies

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. We also share and disclose some cookies with third-parties.

More specifically, we use cookies and other tracking technologies for the following purposes:

• Assisting you in navigation;
• Assisting in registration to our events, login, and your ability to provide feedback;
• Analyzing your use of our products, services or applications;
• Assisting with our promotional and marketing efforts. (including behavioral advertising)

The cookie preference tool, which you can click on at the bottom of the Website contains a detailed list of the cookies we use on our Website, and allows you to customize the cookies we store for you. Our Website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. We classify cookies in the following categories:

• Strictly Necessary Cookies
• Performance Cookies
• Functional Cookies
• Targeting Cookies

 

Children’s Data

Company does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 without the permission of such minor’s parents or legal guardians.

Third Parties

Third-Party Service Providers

Third-party service providers acting on our behalf must execute agreements including confidentiality requirements and will only process Personal Data as necessary to perform their functions in a manner consistent with this Notice, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations. Our third-party service providers may be located in the United States and other jurisdictions.

Combination of Data With Data Received from Third Parties 

We may combine information we collect, whether Personal Data or not, with Personal Data that we may obtain from third parties.

Links to Other Websites

Our Products or Services may contain links to other websites, applications, products, or services that are not owned or operated by Company, such as social media websites and applications like Facebook and Twitter. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.

 

Your Rights Regarding Your Personal Data

Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Data about you (e.g., your contact information). For example, when you contact customer service representatives, we may require you to provide information to authenticate your identity to assist you with your request. If you are unable to provide this information, we may be unable to process your request.

You may have a right under your area’s data protection law to the following rights with respect to some or all of your Personal Data:

• To request access to your Personal Data;
• To request that we rectify or erase your Personal Data;
• To request that we restrict or block the processing of your Personal Data (including to object to the sharing of your Personal Data under other relevant laws);
  • This includes the right to opt-out of solicitations;
• To provide your Personal Data directly to another organization, i.e., a right to data portability;
• When we previously obtained your consent, to withdraw consent to processing.

You can make a request with respect to your Personal Data by completing the form located here. You can also, if you prefer, contact ConsumerCare_USA@reckitt.com or 1-800-228-4722.

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor the request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

 

Rewards Programs

We offer a variety of rewards programs and sweepstakes. To the extent applicable, you may be entitled to know the nature of these financial incentives and how we value your Personal Data collected from these programs. Through these offerings, consumers provide us with some Personal Data when they opt-in to our programs. There is no obligation to opt-in and consumers can opt-out at any time. If you join a rewards program, we use the Personal Data that you provide to better engage with you. Generally, we do not assign monetary or other value to your Personal Data. We may award you with points for signing up for a program or participating in events. Those points can be put towards product purchases. We do not assign points based on the sharing of Personal Data. We would calculate the value of your Personal Data to our business as equal to the value of any financial incentives that you may have received through the programs. You can opt-in to, or opt-out of, our programs at any time through the same means they are offered or by contacting us at ConsumerCare_USA@reckitt.com.

Transfer of Personal Data Across National Borders

Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction where the privacy laws may not be as protective as those in your location, including the United States. Company has put in place lawful transfer mechanisms and adequate safeguards, in accordance with applicable legal requirements, to protect your Personal Data.

Safeguarding Information

Consistent with applicable laws and requirements, Company has put in place physical, technical, and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Products and Services.

How Long Your Personal Data Will Be Retained

We generally retain Personal Data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary business purposes. Whenever possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the specified retention period.

Changes to This Privacy Notice

We reserve the right to change this Notice from time to time. We will alert you when changes have been made by indicating the date this Notice was last updated as the date the Notice became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Notice to learn of any changes.

Contact Us

If you have questions or comments about this Notice or about how your Personal Data is processed, please contact ConsumerCare_USA@reckitt.com or 1-800-228-4722. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor the request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.