NEWELL BRANDS PRIVACY POLICY

Last modification: v1.02 19th July 2018

1. At Newell Brands, we strive to honor the privacy and security of our users, customers and suppliers, as well as their representatives, in relation to all products, services, applications and websites provided by Newell Brands Inc and any of its affiliates acting as a Controller under relevant data protection rules and regulations. You can find a list and contact details of such Newell Brands Controller entities including the responsible controller for this website on the following page Newell Brands Data Controllers and Supervisory Authorities.

If you have any questions or comments regarding this policy or data privacy at Newell Brands, please contact us at Data Privacy Enquiry .

PERSONAL DATA

2. When you submit a request or electronically pass information to any Newell Brands entity (including, but not limited to, contact details), you are sometimes asked to provide certain information, including, but not limited to, your name, title, company, address, phone number, e-mail address and line of business. You may also be providing us with data regarding your device, your client or supplier account, etc. These kinds of data will in many circumstances be considered as personal data under applicable data protection legislation.
3. Please consult the table below to see for which purposes we process (use, store, etc.) personal data, as well as the legal grounds for such processingand the relevant retention period.
Purpose Categories of Personal Data Legal Grounds Retention period (max*)
Customer management (provision of services; invoicing; customer support; …) Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …) Personal characteristics of data subjects and, in some cases family members (age, gender, civil status, …)
Performance/conclusion of a contract with you
Legitimate interests of Newell Brands in managing our customer relationships*
Legal obligation to process data
Up to 10 years after date of last order or end of contract, unless longer period required by law or for litigation
Direct consumer sales customer management (provision of services; invoicing; customer support; …) Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …)
Personal characteristics (age, gender, civil status, …)
Performance/conclusion of a contract with you
Legitimate interests of Newell Brands in managing our customer relationships*
Legal obligation to process data
Your consent
Up to 10 years after date of last order or end of contract, unless longer period required by law or for litigation
Know your customer (anti-fraud; anti-money-laundering; …) Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …)
Personal characteristics (age, gender, civil status, …)
Performance/conclusion of a contract with you
Legitimate interests of Newell Brands in managing our customer relationships*
Legal obligation to process data
Up to 10 years after date of last order or end of contract, unless longer period required by law or for litigation
Direct marketing** Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Legitimate interests of Newell Brands in promoting and improving our products and services*
Your consent
Supplier management (accounting; …) Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …)
Personal characteristics (age, gender, civil status, …)
Performance/conclusion of a contract with you
Legitimate interests of Newell Brands in managing our supplier relationships*
Legal obligation to process data
Up to 10 years after date of last order or end of contract, unless longer period required by law or for litigation
Maintaining the security of our people and assets Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …)
Personal characteristics (age, gender, civil status, …)
Performance/conclusion of a contract with you
Legitimate interests of Newell Brands in protecting our business and employees*
Legal obligation to process data
Typically up to 30 years in the event of physical harm or damage to property
Litigation management Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …)
Personal characteristics (age, gender, civil status, …)
Performance/conclusion of a contract with you
Legitimate interests of Newell Brands in protecting our business and defending our legal interests*
Legal obligation to process data
Up to 10 years after resolution of the dispute
Product/service improvement & business intelligence Identification data (name, address, telephone, ...)
Electronic identification data (e-mail, IP-addresses, cookies, ...)
Financial characteristics (bank account number, credit card details, …)
Personal characteristics (age, gender, civil status, …)
Legitimate interests of Newell Brands in promoting and improving our products and services*
Your consent
Up to 10 years from product discontinuation
* Retention periods vary depending on the type of document containing the personal data. For more information regarding the retention periods, please contact us through the contact details indicated above.
** Based on a balancing test. For more information, see above for our contact details. *** If you wish to object to the use of your personal data for these purposes, see section 9.3 below.
4. We endeavour to ensure that personal information is kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable. However, some personal data may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.Where the personal data are no longer needed for the purpose for which they were collected, we delete your personal data with the exception of such data that we are required to retain for the purpose of contractual or statutory (e.g. taxation) retention periods (e.g. invoices). Data that is only retained because it is subject to a retention period is restricted from processing until the period expires and will then be deleted.
5. In addition, we may, pursuant to valid legal process, such as a search warrant, subpoena, or court order, allow access to any information (including such categories of personal data) provided to Newell Brands, in order to comply with such process and to protect our rights and property. If warranted, we may also allow access to this information in special emergencies where physical safety is at risk.

Newell Brands moreover reserves the right to disclose any information obtained from or about you to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of Newell Brands’ assets.
6. Except as otherwise set forth herein, we do not sell, trade, or rent your personal data with any third parties outside of Newell Brands.

DATA TRANSFERS

7. These categories of personal data may be transferred to other Newell Brands entities for such purposes, as well as to any third parties to whom the relevant Newell Brands entity subcontracts all or part of this processing. This may for instance include e-marketing service providers, hosting providers and any other relevant roles.
8. In the event of transfer of personal data to a country outside of the European Economic Area, Newell Brands systematically ensures the application of an adequate level of protection of such personal data by approved means (e.g. selecting “Privacy Shield”-certified processors or putting in place standard contractual clauses on the processing of personal data, in accordance with the EU Commission model clauses). You can request more information about such measures (including copies where relevant) by getting in touch with Newell Brands through the contact details above.

YOUR RIGHTS

9. Subject to applicable law, you may have some or all of the following rights in respect of your personal data. You can exercise these rights by submitting your request (i) using our Subject Access Request or (ii) to your local customer service team. Please note that Newell Brands may reject requests that are excessive or a misuse of the relevant right.
9.1 Access right. You may have the right to obtain confirmation of whether Newell Brands processes personal data in relation to you and, if so, gain access to a copy thereof. For certain kinds of data, you may also have a right to data portability.
9.2 Data accuracy: right of rectification and right to erasure. You may have the possibility to rectify or obtain the erasure of your personal data, provided that the applicable legal requirements are met. The right to erasure is subject to various exceptions, notably as regards personal data whose processing is necessary to support litigation or for compliance with statutory retention requirements.
9.3 Limits to processing: right to restriction, right to object & consent withdrawal. In addition, you may have the right to object to the processing of personal data based on Newell Brands’ legitimate interests (see table above) and to otherwise obtain the restriction of certain forms of processing in specific circumstances. In particular, in relation to the processing of personal data for direct marketing purposes, you may have the right to object at any time thereto. Where any processing is based on consent, you may have the right to withdraw such consent at any time (without this affecting the processing prior to the consent withdrawal).
9.4 Right to lodge a complaint with the supervisory authorities. You may have the right to lodge a complaint with the supervisory authority, in particular the data protection authority that is competent for your place of residence (see Newell Brands Data Controllers and Supervisory Authorities) or the lead supervisory authority for Newell Brands, namely The Information Commissioner’s Office of Wycliff House, Water Lane, Wilmslow, Cheshire SK9 6AF, United Kingdom, https://ico.org.uk/.

CHILDREN

10. Newell Brands does not knowingly collect information from children. If Newell Brands learns that a child has provided it with personal data, it will use reasonable efforts to remove such information from its files.

USER’S ACKNOWLEDGMENT OF THIS PRIVACY

11. By visiting the Web Site, you acknowledge that you have (had the opportunity to) become familiar with Newell Brands’ privacy policy.
12. We reserve the right, at our sole discretion, to change, modify, add, or remove portions from this privacy policy at any time. We shall notify any such changes in according with applicable data protection legislation.

COOKIES & OTHER MEANS OF IDENTIFICATION

13. Our websites use cookies, pixel tags and other forms of identification and local storage (together referred to as “tags/files” hereunder) to distinguish you from other users of our website and of websites of our network. This helps us provide you with a good experience when you browse our website and websites of our network and also allows us to improve our website and our services.
14. In many cases, these tags/files lead to the use of your device’s processing or storage capabilities. Some of these tags/files are set by Newell Brands itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.
15. These tags/files can fall into several categories: (i) those that are necessary for functionality or services that you request or for the transmission of communications (functionality tags/files); (ii) those that we use to carry out performance and audience metrics regarding our website (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).
16. Internet browsers allow you to change your cookie settings, for instance to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/.
17. Functionality tags/files do not require your consent. For analytical and other tags/files, however, we request your consent before placing them on your device. You can give your consent by continuing to use our website, or by clicking on the appropriate button on the banner displayed to you.
18. You can find out more information about the cookies that we use on our websites by reading our cookie policies using the links provided on our websites.
19. You can find more information about cookies and similar tags/files at the following addresses:
- http://www.allaboutcookies.org/
- http://www.youronlinechoices.eu/ (a guide to behavioral advertising and online privacy, produced by the internet advertising industry).