Privacy policy

(“Essity” or "we" or "us") takes data privacy seriously. This Privacy Policy describes how Essity as controller within the meaning of the General Data Protection Regulation ("GDPR") and the ePrivacy Regulation ("ePrivacy Regulation") collects and processes the personal data and other information of the users.

1. Categories of personal data and processing purposes

Metadata
You may use our website or app without providing any personal data about you. In this case, Essity will 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
If you create an account 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, 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 our website or app, Essity collects and processes the following personal data about you: Your account data, 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.
 
Sweepstakes:
If you participate in a sweepstake, Essity collects and processes the following personal data about you: Name, postal address, email address, date of entry, selection as winner, prize, answer to quiz. Essity processes such personal data for purposes of carrying out the sweepstake, informing the winner, delivering the price to the winner, carrying out the event, 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. Health data are sensitive data within the meaning of the GDPR and Essity is taking all necessary steps to protect such sensitive data as legally required. Subject to your consent, 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 tailored marketing. 

2. Third Parties

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 being involve in the merger or acquisition.
 
International transfers of Personal Data
The 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"). The countries include those listed at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm which provide an adequate level of data protection from a European data protection law perspective. Other recipients might be located in other countries which do not adduce an adequate level of protection from a European data protection law perspective. Essity will take all 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 approved certification mechanisms together with binding and enforceable commitments of the recipient. You can ask for a copy of the such appropriate safeguards by contacting us as set out in Sec. 7 (Contact us) below.

3. Legal basis for the processing

We may carry out the processing of your personal data on the following legal basis:
 
  • 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. 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. 7 (Contact us) below.
 
In case of complaints you also have the right to lodge a complaint with the competent data protection supervisory authority.

5. Cookies and other tracking technologies

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

6. 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 of 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.

7. Competition T+C's

Full Terms & Conditions
These Terms and Conditions prevail in the event of any conflict or inconsistency with any other communications, including advertising or promotional materials relating to the Prize Promotion. Entry instructions are deemed to form part of the Terms and Conditions and by participating all participants will be deemed to have accepted and be bound by the Terms and Conditions.  Please retain a copy for your information. 
 
1. Promoter: Essity UK Ltd, Southfields Road, Dunstable, Bedfordshire, LU6 3EJ.
 
2. The prize promotion is open to UK residents (England, Scotland, Northern Ireland and Wales) only, aged 18 years or over excluding employees and their immediate families of the Promoter, agents or anyone professionally connected with the prize promotion.
 
3. Internet access and Facebook account required to enter.
 
4. Promotional Period: the prize promotion opens at 00:01 on Monday 8th March 2021 and closes at 23:59 on Thursday 1st April 2021. 
 
5. Entry instructions: to enter the prize draw, provide your first name, surname and contact email address on the form.
 
 
6. Only one entry per person. All other entries will be disqualified. 
 
7. No third party or bulk entries. If it becomes apparent that either a consumer group, participant or household is using any means to circumvent this condition such as, and without limitation, multiple Facebook accounts, multiple reproduced or computer-generated entries, using multiple identities, fraudulently falsifying data, acting fraudulently or dishonestly in the opinion of the Promoter or otherwise acting in violation of these terms, these participants will be disqualified, and any prize entitlement will be void.
 
8. Entrants who make an entry on someone else’s behalf will be disqualified, at the Promoter’s discretion. 
 
9. Incomplete, illegible, misdirected or late entries will not be accepted. Proof of sending will not be accepted as proof of delivery or receipt. The Promoter accepts no responsibility for any entries that are incomplete, illegible, corrupted or fail to reach us for any reason.
 
10. Winner Selection: The winner will be randomly selected by an independently verified random computer generator from all valid entries within 7 working days of the closing date (1st April 2021).
 
11. Winner Notification: The winner will be notified by email via the address provided at point of entry within 7 working days of the draw date and will have 14 days from first notification to claim their prize. If the winner does not claim their prize within this timeframe, reject the prize or are ineligible, the Promoter reserves the right to withdraw prize entitlement and will award the prize to a reserve drawn at the same time as the original.  The process will repeat until an eligible winner is able to claim the prize.  Entrants are encouraged to monitor their email account during this time in case they are the winner. 
 
12. Prize Fund: There is one winner. The prize is a year’s supply of lights by TENA. A year’s supply consists of 48 packs Prize will be dispatched by post within 28 working days of acceptance and the completion of any verification process. 
 
13. Covid-19: The Promoter shall not be liable in any way for its inability to meet delivery timeframes in the event of any circumstances resulting from Covid-19 which affect the prize delivery supply chain. Should Covid-19 affect the ability to meet these deadlines, the Promoter will fulfil its obligations as soon as it is reasonably possible.
 
14. No cash or other alternative prize will be provided in whole or in part, except that in the event of circumstances outside of its control, the Promoter reserves the right to substitute the prize with another of equal or greater value should circumstances outside its control make this necessary. The prize is non-transferable. 
 
15. It is the responsibility of the entrant to provide correct, up-to-date details when entering the prize promotion and acceptance of the prize. The Promoter cannot be held responsible for the winner failing to supply accurate information which affects prize acceptance or delivery of their prize.
 
16. The Promoter reserves the right to verify the winner and ask for proof of identity, age and address and to withdraw prize entitlement where there are reasonable grounds to believe there has been a breach of these Terms and Conditions.
 
17. The winner may be asked to take part in reasonable publicity without payment. Such publicity may include, without limitation, publishing the winner’s name, their image and any statements made by them concerning the prize promotion and the prize won as part of the prize promotion on the lights by TENA social channels and website. 
 
18. General: Promoter’s decision is final and binding. No correspondence will be entered into. Entry implies acceptance of these terms and conditions. 
 
19. The Promoter will not tolerate anyone who posts or is seen to be posting comments via any social media channel or anywhere else during this prize promotion that we think are bullying, spiteful or upsetting to other entrants and followers of lights by TENA or directly aimed at us. Anyone acting in this way will be disqualified from the prize promotion.
 
20. The name and county of the winner can be obtained by sending an email, 28 days after the closing date, to  tenalady@tena.co.uk. Participants may request their surname and county are not published in the event they win by emailing tenalady@tena.co.uk before the closing date. In such circumstances, the Promoter must still provide the surname and county of the prize winner to the Advertising Standards Authority on request.
 
21. The Promoter reserves the right, at its sole discretion, to eliminate or disqualify any entries or entrants that it regards as being in breach of these Terms and Conditions or the spirit of the Promotion. Those who try and circumvent the entry process and/or entry instructions by any method, will be disqualified and any prize award will be void.
 
22. If an act, omission, event or circumstance occurs which are beyond the reasonable control of the Promoter and which prevents the Promoter from complying with these Terms and Conditions the Promoter will not be liable for any failure to perform or delay in performing its obligation.
 
23. If any of these clauses should be determined to be illegal, invalid or otherwise unenforceable then it shall be severed and deleted from these Terms and Conditions and the remaining clauses shall survive and remain in full force and effect.
 
24. Limitations of liability: Neither the Promoter, its Agents or anyone professionally connected to the prize promotion, assume any responsibility or liability for: any incorrect or inaccurate personal data entry, or for any faulty or failed electronic data transmissions. Communications line failure, regardless of cause, with regards to any equipment, systems, networks, lines, satellites, servers, computers or providers utilised in any aspect of this promotion. Inaccessibility or unavailability of the internet or Facebook page or any combination thereof. The Promoter or its Agents shall not be liable for any loss (including, without limitation, indirect, special or consequential loss or loss of profits), expense or damage which is suffered or sustained (whether or not arising from any person’s negligence) in connection with this promotion or accepting or using the prize, except for any liability which cannot be excluded or limited by law (including personal injury, death and fraud). 
 
25. The Promoter reserves the right to cancel, amend, withdraw, terminate, or temporarily suspend this prize promotion in the event of any unforeseen circumstances or technical reason outside its reasonable control, with no liability to any entrants or third parties but will use all reasonable endeavours to avoid consumer disappointment. Such circumstances include, but are not limited to: industrial action, civil unrest, fire, flood, storms, earthquakes, acts of terrorism, acts of war, governmental action or any other event that is beyond the control of the Promoter.
 
26. This promotion is in no way sponsored, endorsed or administered by, or associated with Facebook. By entering you understand that you are providing your information to the owner of this Facebook account and not to Facebook. By entering the promotion, all participants accept that they have no claim against Facebook and agree to a complete liability release for Facebook. 
 
27. Numerous factors outside the control of the Promoter may interfere with the operation of Facebook. The Promoter does not therefore guarantee continuous, uninterrupted or secure access to this website. 
 
28. The Promotion and these Terms and Conditions, and any disputes arising therefrom, shall be subject to English law and the exclusive jurisdiction of the English and Welsh Courts.
 
29. Any personal data submitted by participants will be processed by the Promoter and a third-party agency for the purposes of the administration of this prize promotion and prize distribution only. Data processed by the Promoter will be processed in accordance with current Data Protection legislation and the Promoter's Privacy Policy: https://www.tena.co.uk/lightsbytena/privacy-policy.  You can request access to your personal data, or have any inaccuracies rectified, by sending an email to tenalady@tena.co.uk. By entering the prize promotion, participants consent to their personal data being processed in this way. 
 
30. For any enquiries and/or questions related to this prize promotion, please email  tenalady@tena.co.uk

8. Contact us

If you have concerns or questions regarding this Privacy Policy, please contact us:
 
 
Essity UK Limited 
Southfields Road 
Dunstable
Bedfordshire 
LU6 3EJ 
 
Tel: 0800 655 6022
email: info@tena.co.uk