Privacy Policy

BSN Medical Inc. (together with its affiliates, referred to herein as “Essity” or "we" or "us") takes data privacy seriously. This Privacy Policy describes how Essity collects and processes the personal data (sometimes referred to in this Privacy Policy as “personal information”) and other information of the users of the website or mobile app where this Privacy Policy is posted. Essity is the data controller (or business) within the meaning of the General Data Protection Regulation ("GDPR") and the ePrivacy Regulation ("ePrivacy Regulation"). Please note that some of our apps, sites or services are governed by different privacy policies, so you should review them carefully.

1. Categories of personal data and processing purposes

Metadata

You may use our website or app without directly providing any personal data about you. In this case, Essity will automatically collect only the following metadata that result from your usage: 

Referral page, data and time of access, data volume transmitted, status of transmission, type of web browser, IP address, operating system and interface, language and version of browser software.

Your IP address will be used to enable your access to our website or app. Once the IP address is no longer necessary for this purpose, we will shorten your IP address by removing the last octet of your IP address. The metadata, including the shortened IP address will be used to improve the quality and services of our website or app by analyzing the usage behavior of our users.

Account or Registration

If you create an account or register for a product, sample or service on/in our website or app, you may be asked to provide personal data about you, for example: Name, postal address, email address, selected password, company or organization name, job title, telephone number, bank account details, credit card details, invoicing and delivery address, interests in certain products/services (voluntary), request to receive marketing emails (voluntary). Essity processes such personal data for purposes of providing our services to you, to provide you with marketing materials to the extent permitted by applicable law, and to analyze your interests for marketing purposes. 

Product Orders

If you order a product via this website or an app or service governed by this privacy policy, Essity collects and processes the following personal data about you: Your account data or, if you have not created an account, your name, postal address, email address, telephone number, bank account details, credit card details, invoicing and delivery address, type and amount of product, purchase price, order date, order status, product returns, customer care requests. Essity processes such personal data for purposes of carrying out the contractual relationship and the product order, providing customer care services, compliance with legal obligations, defending, establishing and exercising legal claims, and tailored marketing.

Content of Communications

We collect your email address and other personal data you provide when you contact us or communicate with us.

Sweepstakes and other Promotions

If you participate in a sweepstakes or similar promotion, Essity may collect and process the following personal data about you: Name, postal address, email address, date of entry, selection as winner, prize, answer to quiz or other promotion details. Essity processes such personal data for purposes of carrying out the promotion, informing the winner(s), delivering the prize(s) to the winner(s), and marketing. 

Health Data

If you order some products, Essity may collect and process also information about your health conditions as implied by product order or directly shared with us. Essity takes steps to protect such sensitive data as legally required. Essity collects and processes your health data solely for the purposes of carrying out the contractual relationship and the product order, providing customer care services, compliance with legal obligations, defending, establishing and exercising legal claims, and, with your consent, tailored marketing. 

2. Third Parties

Essity affiliates and subsidiaries

As Essity operates globally, we may share your personal data among the Essity companies worldwide for the purposes described in this Privacy Policy.

Transfer to service providers

Essity may engage external service providers, who act as a data processor of Essity, to provide certain services to Essity, such as website service providers, marketing service providers or IT support service providers. When providing such services, the external service providers may have access to and/or may process your personal data.

We request those external service providers to implement and apply security safeguards to ensure the privacy and security of your personal data. 

Other recipients

Essity may transfer - in compliance with applicable data protection law - personal data to law enforcement agencies, governmental authorities, legal counsel, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties involved in the merger or acquisition. We may also transfer your personal data with your consent.

International transfers of Personal Data

Personal data that we collect or receive about you may be transferred to and processed by recipients which are located inside or outside the European Economic Area ("EEA"). Some of those countries may not be deemed to provide an adequate level of data protection from a European data protection law perspective. Essity will take necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, we base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved code of conducts together with binding and enforceable commitments of the recipient, or certification under the EU-U.S. Privacy Shield or other approved certification mechanisms together with binding and enforceable commitments of the recipient. You can ask for a copy of such safeguards by contacting us as set out in Sec. 8 (Contact us) below.

3. Legal basis for the processing

We may carry out the processing of your personal data on the following legal basis, as required by the GDPR:

• You have given your consent to the processing of your data for one or more specific purposes;
• The processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract;
• The processing is necessary for compliance with a legal obligation to which we are subject to;
• The processing is necessary to protect your vital interests of you or of another natural person;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; 
• The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data, in particular if you are a child;
• Other applicable legal basis for data processing, especially provisions set out by member state law;

We may carry out the processing of your sensitive personal data on the following legal basis:

• You have given your explicit consent to the processing of your sensitive personal data for one or more specific purposes; 
• The processing is necessary for the purposes of carrying out the obligations and exercising specific rights of Essity or of the data subject in the field of employment and social security and social protection law;
• The processing relates to personal data which are manifestly made public by the data subject; 
• The processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity; The provision of your personal data is required by a statutory or contractual obligation, or necessary to enter into a contract with us or to receive our services/products as requested by you, or simply voluntary for you. 
• Not providing your personal data may result in disadvantages for you, e.g. you may not be able to receive certain products and services. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.

4. THIRD PARTY SITES AND SOCIAL MEDIA PLATFORMS

The website may contain links to other websites not owned by us and other websites not owned by us may reference or link to our website. We encourage our users to read the privacy policies of each website they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites that we do not own. Visiting these other websites is at your own risk.

The website may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our website. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

5. What rights do you have and how can you assert your rights?

If you have declared your consent regarding certain collecting, processing and use of your personal data, you can revoke this consent at any time with future effect. Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with the basic tariffs.

Pursuant to the applicable data protection law you have the right (i) to request access to your personal data, (ii) to request rectification of your personal data, (iii) to request erasure of your personal data, (iv) to request restriction of processing of your personal data, (v) to request data portability, (vi) to object to the processing of your personal Data (including objection to profiling), and (vii) to object to automated decision making (including profiling). 

To exercise your rights please contact us as stated under Sec. 8 (Contact us) below.

In case of complaints you also have the right to lodge a complaint with the competent data protection supervisory authority.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”) provides you with certain rights with respect to your personal information.

• Right to Access. You have a right to request that we disclose, no more than twice in a 12-month period:
• The categories and specific pieces of personal information we have collected about you.
• The categories and sources from which personal information is collected.
• The business or commercial purposes for collecting or selling personal information.
• The categories of third parties with whom we share personal information.

The categories and specific pieces of personal information we collect, sources from which personal information is collected, and purposes for collecting personal information are described in Section 1 of this Privacy Policy. The categories of third parties with whom we share personal information are described in Section 2 of this Privacy Policy.

We will provide this information upon receipt of a verifiable consumer request. How we will verify your identity depends on how you have interacted with us in the past. To exercise this right, you can contact us by phone at 800-537-1063 or by email at dataprivacy@essity.com.

• Right Delete. You have a right to request that we delete any personal information about you that we have collected from you, subject to certain exceptions. If we are required to delete your personal information, then upon receipt of a verifiable request, we will delete your personal information from our records and direct any service providers to delete your personal information from their records. To exercise this right, you can contact us by phone at 800-537-1063 or by email at dataprivacy@essity.com.
• Right to opt-out. You have a right to opt-out of the “sale” of your personal information to third parties. We share certain personal information with third parties under circumstances that might be deemed a “sale” under the CCPA, such as when we allow advertising technology partners to use cookies and other technologies to collect your information and present advertising messages based on your preferences and to help us identify other users likely to be interested in our products and services. For more information or to opt-out, you can contact us at dataprivacy@essity.com or click here

Under California Civil Code Section 1798.83, California residents have a right to request, once per year and free of charge, information about the categories of personal information (if any) we have disclosed to third parties for their direct marketing purposes during the previous calendar year. If you are a California resident and would like to make such a request, please send an email to dataprivacy@essity.com with the subject line “California Shine the Light Request.”

Nevada Privacy Rights

Nevada residents have a right to submit a verified request directing a website operator to not make any “sale” of covered information collected about a consumer for monetary consideration to a person for such person to license or sell the information to additional persons, subject to certain exceptions. We do not engage in the “sale” of covered information, as that term is defined.

6. Cookies and other tracking technologies

This website or app uses cookies. For further information please visit our Cookie Policy

7. How long do we keep your Personal Data?

Your personal data will be retained as long as necessary to provide you with the services and products requested. Once our relationship has come to an end, we will either delete your personal data or anonymize your personal data, unless statutory retention requirements apply (such as for taxation purposes). We may retain your contact details and interests in our products or services for a long period of time if Essity is allowed to send you marketing materials. Also, we may be required by applicable law to retain certain of your personal data for a period (for example, 10 years after the relevant taxation year). We may also retain your personal data after the termination of the contractual relationship if your personal data are necessary to comply with other applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need to know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship.

8. Contact us

If you have concerns or questions regarding this Privacy Policy, please contact us:

BSN Medical Inc., as Essity Company
5825 Carnegie Blvd.

Charlotte, NC 28209-4633
Tel: 1-800-537-1063 or 1-704-554-9933
dataprivacy@essity.com

The contact details of our data protection officer are as follows:

Iris Winter
Compliance Officer Data Protection
Group Function Sustainability
Quickbornstraße 24
D-20253 Hamburg, Germany
Tel: +49 40 4909-6546
iris.winter@bsnmedical.com