US-EU SAFE HARBOR PRIVACY STATEMENT
It is the policy of Reckitt Benckiser LLC (USA) (“Reckitt Benckiser LLC”) to respect Personal Information, including Sensitive Personal Information, that is collected or maintained by or on behalf of Reckitt Benckiser LLC. In furtherance of this commitment, Reckitt Benckiser LLC adheres to the US-EU Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this US-EU Safe Harbor Privacy Statement (the “Privacy Statement”) and the Principles, the Principles shall govern. This Privacy Statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This Privacy Statement applies to all Personal Information received by Reckitt Benckiser LLC whether in electronic, paper or verbal format.
“Personal Information” or “Information” means information that (1) is transferred from the European Union to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
Reckitt Benckiser LLC shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which Reckitt Benckiser LLC discloses or may disclose that Information. Reckitt Benckiser LLC shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Reckitt Benckiser LLC, or as soon as practicable thereafter, and in any event before Reckitt Benckiser LLC uses or discloses the Information for a purpose other than for which it was originally collected.
Reckitt Benckiser LLC will offer individuals the opportunity to choose (i.e., “opt out”) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, Reckitt Benckiser LLC will give individuals the opportunity to affirmatively or explicitly consent (i.e., “opt in”) to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Reckitt Benckiser LLC shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
Reckitt Benckiser LLC only transfers Personal Information to third parties that have provided written assurances that they have at least the same level of privacy protection as is required by the Principles. Where Reckitt Benckiser LLC has knowledge that a third party is using or sharing Personal Information in a way this is contrary to the Principles, Reckitt Benckiser LLC will take reasonable and appropriate steps to prevent or stop such processing.
Reckitt Benckiser LLC shall take reasonable steps (including the implementation of appropriate physical, electronic and managerial procedures) to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Reckitt Benckiser LLC cannot guarantee the security of Information on or transmitted via the Internet.
Reckitt Benckiser LLC shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Reckitt Benckiser LLC shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Reckitt Benckiser LLC shall allow individuals access to their Personal Information and allow individuals to correct, amend or delete inaccurate Information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Reckitt Benckiser LLC uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that it is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. Reckitt Benckiser LLC encourages affected individuals to contact Reckitt Benckiser LLC (contact information provided below) with any complaints or disputes regarding this Privacy Statement or Reckitt Benckiser LLC’s use and disclosure of Personal Information in accordance with the Principles and Reckitt Benckiser LLC will investigate and attempt to resolve these complaints using internal processes.
If a complaint or dispute cannot be resolved by Reckitt Benckiser LLC, or if Reckitt Benckiser LLC does not provide timely acknowledgement of a complaint or dispute, affected individuals may then contact:
Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Web: www. us.bbb.org
Reckitt Benckiser LLC has agreed to the submission of unresolved complaints or disputes to the Council of Better Business Bureaus, Inc., the BBB EU Safe Harbor, an independent third-party dispute resolution provider.
This Privacy Statement may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.
Questions, comments or complaints regarding Reckitt Benckiser LLC’s Safe Harbor Policy or data collection and processing practices can be mailed or faxed to:
Reckitt Benckiser LLC (USA)
399 Interpace Parkway
P.O. Box 399
Parsippany, NJ 07054-0225
Attn: Legal Department
Effective date: January 31, 2010
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