We, at Ferrero, are committed to respecting the right to data protection and the right to privacy of our consumers (“you”). In line with this commitment, we wish to provide you with this privacy notice (“Notice”), in which we explain the way we collect, process, share, store and otherwise handle your personal data in the context of the Add Your Golden Touch activation in South Africa.
1. Who are we and how to contact us?
The Ferrero Group has established its headquarters at Route de Trêves 16, L-2633 Senningerberg, Luxembourg. When collecting and processing your personal data in the context of the Add Your Golden Touch activation, Ferrero Trading Lux S.A, with registered office in Luxembourg, Route de Trèves 16, 2633 Senningerberg, acts as a responsible party (also known as a data controller).
If you have any questions on the processing of your personal data in the context of the Add Your Golden Touch activation, do not hesitate to contact the Ferrero headquarters' Data Protection Officer ("DPO") by sending an email to the details listed in 8 below.
2. What personal data do we collect, for what purpose and on what legal basis?
We only collect personal data that may be necessary for user participation in the activation, from registration to rewards distribution. Unless otherwise stated by us, we collect this information directly from you, when you provide it to us for purposes of your participation in the activation. In particular, the following types of data will be collected and processed:
- Your name and email address
The supply of this personal data by you to Ferrero is voluntary, however, if you do not provide it we may not be able to facilitate your participation in the activation. The specific purposes and corresponding legal basis for the processing of these distinct categories of personal data are summarized in the table below.
| Type of data | Purpose of the processing | Legal basis |
| Name and email address | User email registration, administration and rewards distribution. | Performance of the contract (Terms of the contest) with you. |
3. How long do we keep your personal data?
Subject to applicable law, Ferrero will keep your personal data as long as is necessary for achieving all the above-mentioned purposes before anonymizing or deleting it, and generally for a maximum of 2 years.
Upon expiration of the above-mentioned retention periods, the personal data will be deleted or anonymized, except if it is still necessary for Ferrero to comply with a legal obligation or to protect or defend its interests, for example in the event of a claim. In these cases, Ferrero may store your personal data for a longer period, for example until the claim is fully handled and resolved.
4. With whom do we share your personal data?
To achieve the above-mentioned purposes, Ferrero will share your personal data with the following categories of recipients:
- Internal Recipients: Marketing and legal department for the process of the reward distribution.
You may further inquire about the identity of the recipients of your personal data by contacting the relevant Ferrero DPO or privacy coordinator (see contact details under 8 below).
5. Do we transfer your personal data to another country?
Generally, your personal data will only be processed in the country where you are located, and in the European Economic Area. To ensure that your personal data receives an adequate level of protection, we have put in place appropriate measures to ensure that your personal information is treated by any third parties in a way that is consistent with, and which respects, the South Africa laws on data protection, including agreements that protect your personal information in accordance with South African laws. If you require further information about these protective measures, you can request it from the DPO (see contact details under 8 below).
6. Do we use your personal data for automated decision-making?
We will never use your personal data in the context of automated decision-making. In other words, no decision having a legal effect on you, or a similarly significant effect will be taken only by automated means. The processing of your personal data is always subject to human oversight.
7. What are your data protection rights?
You have several rights in relation to the processing of your personal data:
- the right to obtain additional information or clarifications on the processing of your personal data, and to obtain a copy of your personal data;
- the right to obtain the correction of your personal data if they are inaccurate or incomplete;
- the right to object to the processing of your personal data on grounds relating to your particular situation whenever the processing is based on our legitimate interests;
- the right to obtain restriction of processing from us (i.e., temporary suspension of the processing) while we assess the validity of another request relating to your personal data;
- the right to data portability (i.e., the right to receive your personal data in a commonly used and machine-readable format and transmit them to another responsible party);
- the right to request the erasure of your personal data (i.e., the ‘right to be forgotten’); and
- the right to withdraw your consent whenever consent is the legal basis for the processing.
You may exercise these rights at any time by contacting the relevant Ferrero DPO or privacy coordinator (see contact details under 8 below). Please note that, subject to applicable law, these rights are not absolute and may be subject to specific conditions. If you contact us to exercise one of these rights, we will analyze your request and get back to you as soon as possible.
In the event you believe that Ferrero did not handle your request properly or infringed any applicable data protection laws that apply, you may file a complaint with the Luxembourg data protection authority (the Commission Nationale pour la Protection des Données), in its capacity as lead supervisory authority, or with your national or local data protection authority.
8. Privacy email address per country or region
Feel free to contact the DPO of Ferrero HQ in Luxembourg at privacy@ferrero.com.