Nutella 60 Years Celebration
Privacy Policy
This Privacy Policy describes how Ferrero UK Limited, in its capacity of Data Controller (hereinafter, the “Company” or “Controller” or “Ferrero”), with registered office at 889 Greenford Road, Greenford, UB6 0HE, United Kingdom, processes personal data of those who participate to the contest Nutella 60 years of smiles (hereinafter “Nutella 60 years of smiles”) though a dedicated platform (hereinafter, the “Platform”).
Participation to the Nutella 60 years of smiles is governed by the Terms & Conditions available on the contest’s dedicated Platform.
Any information and data provided, or which is otherwise gathered by Ferrero in the context of the participation to Nutella 60 years of smiles, will be processed by Ferrero in strict confidentiality and in accordance with the applicable privacy legislation, including Section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”); and UK Data Protection Act 2018 (“DPA 2018”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the (“Applicable Privacy Laws”)
Ferrero has appointed a Data Protection Officer (DPO). For any information regarding the processing of personal data by Ferrero, including a list of its data processors, please contact: [email protected]
1. Personal data processed
The participant may provide some personal information when deciding to participate to Nutella 60 years of smiles. The following personal data will be requested and processed by Ferrero:
– First and last name;
– E-mail address;
Hereinafter, commonly defined as “Personal Data”.
2. Purposes and legal basis of processing
Ferrero collects and processes Personal Data for the participation in the contest Nutella 60 years of smiles.
Personal Data provided by participants will be used exclusively for the following purposes:
a) pre-contractual and contractual obligations, as well as to manage the Nutella 60 years of smiles and to ensure its correct and regular execution in accordance with the regulations and the Terms & Conditions governing it (e.g., list of subjects entitled to participate, respect of the guidelines provided for posting the pictures, etc.);
b) administrative-accounting purposes as well as for the performance of organisational, administrative, financial or accounting activities, such as internal activities functional to the fulfillment of contractual and pre-contractual obligations;
The legal basis for the processing of Personal Data for the pursuit of these purposes is the execution and the proper management of the contract and the participation in the Nutella 60 years of smiles pursuant to Art. 6, par. 1, lett. b) UK GDPR.
c) consent to publish the picture on the Nutella’s wall pursuant to Art. 6, par. 1, lett. a) UK GDPR.
Consent can be withdrawn at any time. This will have no personal consequences except that failure to provide the Personal Data will render it impossible to participate in the contest.
d) legal obligations, or to fulfill obligations established by law, by a regulation or by national legislation (e.g., tax legislation);
The legal basis of the processing of the Data processed for this purpose is the fulfilment of obligations provided for by law and applicable regulations pursuant to Art. 6, par. 1, lett. c) UK GDPR.
e) handling of disputes in the event of non-compliance, breaches, legal claims and/or transactions;
f) to prevent and detect any misuse or any fraudulent activities carried out through the website.
The legal basis for the processing of Personal Data for the purposes described is the pursuit of a legitimate interest of the Company and/or third parties (e.g., in the case of disputes) pursuant to Art. 6, par. 1, lett. f) UK GDPR.
3. Nature of the provision of Personal Data and consequences of any refusal
4. Third Parties and Data Transfer
Personal Data provided or collected will be processed by properly trained personnel. Ferrero may also request its service providers to perform some data processing operations on its behalf, according to the instructions provided by the same and in line with this Privacy Policy.
Specifically, Personal Data may be communicated, within the limits strictly relevant to the obligations, tasks and purposes referred to Nutella 60 years of smiles and in compliance with current legislation, to the following categories of subjects:
a) Partners (natural and / or legal persons) who provide services to the activities of the Data Controller for the management of the Platform;
b) selected individuals authorized by Ferrero to process Personal Data needed to carry out activities strictly related to the provision of the services through the website (e.g. technical maintenance of network equipment and electronic communications networks), who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Ferrero);
c) other companies within the Ferrero Group for internal administrative purposes;
d) public entities, bodies or authorities, in accordance with the applicable law or binding orders.
Personal Data may be transferred to countries within the European Economic Area, in particular in all the countries where the Data Controller has a legal entity belonging to the group. Accordingly, Personal Data will be transferred in compliance with the requirements and the obligations provided by applicable data protection laws.
5. Retention
Personal Data will be stored for a limited time, i.e. for the duration of the contest. At the end of the contest, all Personal Data will be permanently deleted from all Ferrero’s servers.
6. Children
Ferrero does not knowingly collect or process the data of minors. Should this become apparent to Ferrero at any point, Ferrero will take appropriate steps to ensure its deletion.
7. Rights
In relation to the processing activities described in this Privacy Policy, data subjects can exercise the following rights:
a) obtain confirmation of the existence of their personal data and gain access to them (right to access);
b) obtain the updating, modification and/or rectification of their personal data (right to rectification);
b) request the deletion, anonymisation or restriction of the processing of Personal Data processed (right to be forgotten and right to the restriction of processing);
c) object in whole or in part, on legitimate grounds, to the processing of the Personal Data (right to object);
d) to withdraw the consent to the processing of the Personal Data (if and to the extent such a consent is necessary);
e) receive a copy of the Personal Data in a machine-readable format (right to data portability); and
f) the right to lodge a complaint with the UK Supervisory Authority at https://ico.org.uk/make-a-complaint/.
To exercise all the rights identified above, simply contact the Data Controller by sending an e-mail to [email protected].