Promotional Privacy Policy

1. RB UK Commercial Limited (the ‘Promoter’) is a company registered in England & Wales under company number 08784077, with registered office at 103 – 105 Bath Road, Slough, Berkshire, SL1 3UH, United Kingdom, and is in the role of data controller responsible for the processing of personal data. The Promoter is committed to protecting the data privacy rights of all participants, in strict compliance with any applicable Data Protection Law in the UK, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The Promoter confirms that any personal data, processed in connection with the Promotion, will only be collected, saved or processed for the purposes of the “Durex Spinning Wheel Promotion”.

More details on Promoter general processing of personal data are available here.

2. Categories of personal data – Within the Promotion, the Promoter will collect from the participants the following categories of personal data through designated online form accessible from Durex website: participants’ full name and email address in order to subscribe the Participants to Promoter´s general newsletter covering news related to Durex brand and provide the Participants with relevant prize indicated on the prize label within the Spinning Wheel.

3 Purpose of the processing and legal basis – Participants’ personal data submitted in connection with the Promotion will be processed by the Promoter for the purpose of i) subscribing the Participants to Promoter's general newsletter covering news related to Durex brand and ii) providing the Participants will relevant prize indicated on the prize label within the Spinning Wheel. Legal basis for the processing of participants’ personal data is consent for promoting the Promoter’s products related to designated brands in portfolio via email as part of broader Promoter’s direct marketing strategy [i.e., art. 6 (1) (a) (UK) GDPR]. Legal basis for providing the Participant with the relevant prize and its administration during checkout is these Terms & Conditions, which represent a contractual agreement between Participants and the Promoter [i.e., art. 6 (1) (b) (UK) GDPR].

4. Data retention – The Promoter will only retain participants’ personal data as long as reasonably required for the purposes as set out in this privacy policy or otherwise to comply with legal or regulatory requirements applicable to the Promoter. When participants’ personal data is processed (i) for the performance of a contract with the Promoter, the Promoter retains participants’ personal data for a period of 7 years following the end of the Promotion; (ii) for meeting legal and regulatory requirements, the Promoter retains participants’ personal data as it is set out by applicable laws; and (iii) in all other cases, participants’ personal data is processed for up to 2 years from the date of last interaction with participants (specifically for marketing purposes unless the participant opts-out from the newsletter distribution).

5. Data sharing – Personal data collected within the Prize Promotion will be accessed, as data processor, by our third-party vendor(s) providing support and assistance in relation to the Promoter’s website and our consumers’ database on the basis of relevant agreements.

6. Transfer to other countries – Personal data may be transferred outside the UK and the EEA, including the USA, by our third party-vendors acting as data processors on our behalf. For the transfer of personal data outside the UK and the EEA, appropriate safeguards have been adopted, including Standard Contractual Clauses adopted by the European Commission and Binding Corporate Rules as applicable within UK.

7. Children – Since individuals aged 18 and over can participate exclusively in the Promotion, no data belonging to persons under the age of 18 will be processed and stored. In the event that the Promoter receives personal data belonging to persons under the age of 18, this data will be immediately deleted/destroyed. If a parent or holder of the parental authority notifies the processing of personal data belonging to persons under the age of 18, the promoter will immediately delete/destroy this data from the processing and storage facilities.

8. The protection of your personal data – The Promoter undertakes to implement appropriate technical and organizational measures in order to ensure a level of security corresponding to the personal data belonging to the participants of the Promotion. In assessing the appropriate level of security, account shall be taken in particular of the risks posed by the processing of personal data, caused in particular, by accident or illegally, by the destruction, loss, modification, unauthorised disclosure or unauthorised access to personal data transmitted, stored or processed.

9. Participants’ data protection rights – In connection with the processing of their personal data within the Promotion, participants have the following rights arising from the GDPR:

• the right of access to personal data including right to request a copy of personal data;
• the right to rectification (right to have their inaccurate personal data corrected or to have incomplete personal data completed without undue delay);
• the right to deletion (right to have their personal data deleted without undue delay, if one of the legal grounds is given);
• the right to restrict processing;
• the right to data portability (in cases stipulated by law, right to obtain their personal data provided to the Promoter in a structured, commonly used and machine-readable format, and the right to pass this data to another data controller);
• the right to object to the processing;
• the right not to be the subject of any decision based solely on automated processing;
• the right to withdraw the consent at any time. To withdraw their consent, participants have to click here.

10. Complaints – Participants have furthermore right to complain to the Information Commissioner (ICO). Details of how to file a complaint can be found on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

11. How to contact the Promoter – Questions, comments or requests concerning the personal data processing are welcomed and should be addressed to privacyoffice@reckitt.com. To opt-out from consent, please click here or use opt-out function at any time through the unsubscribe function in our newsletter.