1. PERSONAL DATA
2. TYPES OF INFORMATION WE COLLECT
3. HOW WE COLLECT INFORMATION
4. OUR PROCESSING PURPOSES AND LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
5. HOW WE SHARE AND/OR DISCLOSE PERSONAL DATA
6. CROSS-BORDER TRANSFER OF PERSONAL DATA 
7. RETENTION OF YOUR PERSONAL DATA
8. HOW WE PROTECT PERSONAL DATA
9. YOUR RIGHTS
10. YOUR RIGHT TO LODGE A COMPLAINT
11. YOUR CHOICES
12. DISCLAIMER THIRD PARTY WEBSITES AND APPS
13. QUESTIONS OR COMPLAINTS

1. PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person. This means information either directly relates to that natural person, or information is traceable to a natural person e.g. by combining this with other information (“personal data”).

Examples of personal data include your name, e-mail address, phone number, postal address, IP address, MAC address, information on website usage, bank account number, credit card details, username, gender, CCTV footage, access information.

2. TYPES OF INFORMATION WE COLLECT

We may collect various types of personal data from you depending upon how you interact with us or use or interact with our Services:

• When you visit our website, we collect your IP-address, MAC-Address and information on website usage.
• When you subscribe to our newsletter, we collect your name, email address, pet recipe, type of pet.
• If you use our customer care service via our website, we collect your name, email address, phone number and any information you include in the “message” field.
• If you interact with us as a consumer offline, we collect your name email address, mobile phone number(s).
• If you interact with us as a distributor, retailer or other business partner, we collect your name, business name, business address, and other business contact details.

We will only collect, use, and disclose personal data if it is necessary to provide you with our Services.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your working relationship with us.

3. HOW WE COLLECT INFORMATION

We collect personal data from you in order to provide you with our Services, as well as to improve your experience using our Services. You may provide us with personal data in several ways, including, for example when you:

• Visit our website, use our Services, or purchase our products (including from any of our retailers);
• Create an account or membership;
• Correspond with us, including through surveys;
• Sign up to receive our newsletter or promotional information;
• Ask for customer service, support or other assistance; or
• Interact with us in any other way, online or offline, including through our Services.

Offline Interactions and Other Sources

We may also collect personal data from other sources (such as our third party service providers, retail stores and/or distributors) or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize the Services for you. The type of data we collect is listed under “Types of information we collect”.

4. OUR PROCESSING PURPOSES AND LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

For the processing of your personal data, we need a purpose. This purpose differs per processing activity. For example, for the sending of our newsletter (the purpose) we process your name and e-mail address.  

We only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Furthermore, we may only process your personal data if we have a legal basis for data processing. If we do not have such legal basis, the data processing will not be lawful. The lawful basis ties in with the processing purpose.

Examples of legal bases are:

• You have given your consent for the processing of your personal data for one or more specific purposes;
• The processing is necessary for the performance of a contract with you or necessary to take steps at your request to enter into a contract with you; or
• The processing is necessary for the purposes of the legitimate interests pursued by us or a third party, but only if your interests, fundamental rights or fundamental freedoms do not outweigh our legitimate interests. Accordingly, we perform a balancing test when using this legal basis. If you would like to receive more information on the outcome of a balancing test for a specific processing activity please contact privacy@championpetfoods.com.

Below you find more information about the purposes for which we process your personal data and on what legal basis we base the processing.

• The purpose for the data processing that relates to our newsletter is to send the newsletter to inform you about news, events, products and offers (direct marketing). Our legal basis for this processing activity is your consent.
• The purpose for the data processing that relates to our customer care service is communicate with assist individuals who call the customer care service. The legal basis for this processing activity is our legitimate interest, namely to communicate and provide individuals with answers, requests and service.
• The purpose for the data processing that relates to our surveys is to improve our Services and customers’ experiences and to understand customers’ preferences. Our legal basis for this processing activity is our legitimate interest, namely to improve our Services.  If our surveys promote our products, then we will seek your consent prior to processing.
• The purpose of the data processing that relates to business contacts is to facilitate and manage our business relationship with distributors and retailers, such as payment management. Our legal basis for this processing activity is that the processing is necessary for our legitimate interest, namely to properly administer our business relationships.
• The purpose of the data processing that relates to our website is maintenance, development and security of the website and the creating of analytical reports. Our legal basis for this processing activity is our legitimate interest, namely providing an up-to-date and safe website environment to website visitors.

5. HOW WE SHARE AND/OR DISCLOSE PERSONAL DATA

Except as set forth in this Privacy Policy, or as required or permitted by law, we do not disclose your personal data to any parties other than listed in this section. The personal data we collect, we share with parties including:

1. Group companies: We will share personal data in our group for administrative, management and accounting purposes, and as part of our regular reporting activities on company performance;
2. Government: If we are legally obliged to do so, we will share data we collect with law enforcement agencies and other governmental bodies.
3. Companies who process personal data on our behalf: We will share personal data with or provide access to third parties who work on behalf of us or provide services to us in this respect. Such companies are, for example:

1. e-mail service providers;
2. marketing services;
3. agency services.

Any company who receives personal data from us will have to comply with this Privacy Policy, data protection rules and security measures we set. Where a data recipient qualifies as a data processor, we will execute a written data processing agreement.

6. CROSS-BORDER TRANSFER OF PERSONAL DATA

We may transfer your information to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal data from the European Economic Area (the EEA) to a country outside the EEA, we will take relevant measures to protect the information in accordance with applicable laws and regulations.

To the extent required by applicable law, for transfers from the EEA to outside the EEA and further transfers from or within non-EEA countries, we use so-called Standard Contractual Clauses (SCCs) as a way to ensure adequate safeguards are in place. The European Commission has approved these model contracts. You can find more information about the SSCs here.

7. RETENTION OF YOUR PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for as set out under Section 4, unless we need to retain the data for satisfying any legal, accounting or reporting requirements, or when needed to establish, exercise, or defend a legal claim.

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

8. HOW WE PROTECT PERSONAL DATA

We are concerned about ensuring the security of your personal data, and we have taken appropriate measures to ensure its security and confidentiality. We exercise great care in providing secure transmission of your information from your browser or device to our servers. We store personal data that we have collected in secure operating environments. We will only retain your personal data for the period of time reasonably required to fulfill the purposes for which it was collected. We may retain non-personal data for as long as we have a business need to do so.

All of our service providers and contractors are contractually obligated to employ appropriate data security measures with respect to your personal data and to collect/use/disclose/retain it only within the scope required for the provision of our Services. The contractors we contract with will use your personal data if required to perform their respective services. These include, for example, IT service providers that we need to operate and safeguard our IT system that stores your personal data.

Our security procedures mean that we may occasionally request proof of identity before we disclose your personal data to you. We try our best to safeguard personal data once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your information, please contact us as soon as possible.

9. YOUR RIGHTS

In accordance with the applicable laws in the European Union, you have the right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability and the right to object. Please note that most of these rights are not absolute and subject to exemptions in the law, may only apply to certain types of personal data or processing. Below we set out your rights in more detail and give personal data on how you can exercise your rights. We will respond to your request within one month, but have the right to extend this period to two months. If we extend the response period, we will let you know within one month from your request.

• Access: you are entitled to ask us if we are processing your personal data and, if we are, you can 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. If your request is clearly unfounded or excessive we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Transfer: you may request the transfer of certain of your personal data to another party. You have the right to ask that we provide your personal data in an easily readable format to another company.
• Objection: where we are processing your personal data based on a legitimate interest (or those of a third party), you may object to processing on this ground.  However, we may be entitled to continue processing your personal data based on our legitimate interests.

In the limited circumstances where you may have provided your consent to the collection and processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time without affecting the lawfulness of processing based on consent before its withdrawal.

If you want to exercise any of these rights, or to withdraw your consent, please contact Champion Petfoods department that is the first point of contact in writing at privacy@championpetfoods.com. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.

10. YOUR RIGHT TO LOGDE A COMPLAINT

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of Data Protection law has taken place. Contact details of the supervisory authorities are available here.

11. YOUR CHOICES

We offer you certain choices in connection with our Services.

Email communications

You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your e-mail address and consent to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

12. DISCLAIMER THIRD PARTY WEBSITES AND APPS

Our Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

When clicking related links or accessing related websites, please pay attention to the security of your personal data, and carefully read the privacy policy of the related party.

13. QUESTIONS OR COMPLAINTS

If you would like to receive additional information specified in this Privacy Policy or have any questions how we handle your personal data or would like to make any complaints, please contact our Champion Petfoods department that is the first point of contact in writing privacy@championpetfoods.com.

For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.