SCOPE OF THIS NOTICE
"Personal Data" refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which We may have access. This includes data that would identify an individual (e.g. name, residential address, personal email address, mobile telephone number or NRIC number.)
This Notice covers both our online and offline data collection activities, including Personal Data that We collect through our various channels such as websites, apps, third party social networks and events. Please note that We might aggregate personal data from different sources (website, offline event). As part of this, We may combine Personal Data that were originally collected by different entities or WNSC partners. Please see Section 9 for further information on how to object to this.
This Notice may be updated from time to time (see Section 11).
By using our websites, applications or by otherwise giving Us your personal information you are accepting the practices describes in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use our websites, applications or give Us any of your personal information. We reserve the right to make changes to this Privacy Notice at any time. Any changes will be posted in this Notice, so, We encourage you to regularly review this Notice to make sure you are aware of any changes and how your Personal Data may be used and disclosed.
This Notice provides important information in the following areas:
- SOURCES OF PERSONAL DATA
- PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
- PERSONAL DATA OF CHILDREN
- COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
- USES MADE OF YOUR PERSONAL DATA
- DISCLOSURE OF YOUR PERSONAL DATA
- RETENTION OF PERSONAL DATA
- STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
- ACCESS TO YOUR PERSONAL DATA
- YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
- CHANGES TO OUR NOTICE
- DATA CONTROLLERS & CONTACT
1. SOURCES OF PERSONAL DATA
This Notice applies to Personal Data that We collect from or about you, through the methods described below (see Section 2), from the following sources:
WNSC websites. Healthcare professional-directed websites operated by or for Wyeth, including sites that We operate under our own domains/URLs and mini-sites that We run on third party websites such as Facebook (“Websites”).
WNSC mobile sites/apps. Healthcare professional -directed mobile sites or applications operated by or for Wyeth, such as smartphone apps.
WNSC engagement. Healthcare professional engagement communications
E-mail, text and other electronic messages. Interactions with electronic communications between you and Wyeth.
Offline registration forms. Printed or digital registration and similar forms that We collect via, for example, postal mail, or events.
Advertising interactions. Interactions with our advertisements (e.g., if you interact with on one of our ads on a third party website, We may receive information about that interaction).
Data We create. In the course of our interactions with you, We may create Personal Data about you (e.g. WNSC events you attended)
Data from other sources. Third party social networks (e.g. such as Facebook, Google), market research (if feedback is not provided on an anonymous basis), third party data aggregators, Wyeth promotional partners, public sources and Personal Data lawfully received when We acquire other companies.
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Depending on how you interact with Wyeth (online, offline, over the phone, etc.), We collect various types of Personal Data from you, as described below.
Personal contact information. This includes any information you provide to Us that would allow Us to contact you, such as your name, postal address, e-mail address, social network details, or phone number
Account login information. Any information that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password in unrecoverable form, and/or security question and answer.
Demographic information & interests. Any information that describes your demographic or behavioural characteristics. Examples include your date of birth, age or age range, gender, geographic location (e.g. postcode/zip code), favourite products, hobbies and interests, and household or lifestyle information.
Information from computer/mobile device. Any information about the computer system or other device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a WNSC website or app via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data.
Websites/communication usage information. As you navigate through and interact with our Websites or newsletters, We use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected through the use of third party tracking for analytics and advertising purposes. Please refer to the Cookie Notice for further details.
Market research & consumer feedback. Any information that you voluntarily share with Us about your experience of using our products and services.
Consumer-generated content. Any content that you create and then share with Us on third party social networks or by uploading it to one of our Websites or apps, including the use of third party social network apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, We collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third party social networking.
Third party social network information. Any information that you share publicly on a third party social network or information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with Us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share. We receive your third party social network profile information (or parts of it) every time you download or interact with a WNSC web application on a third party social network such as Facebook, every time you use a social networking feature that is integrated within a WNSC site (such as Facebook Connect) or every time you interact with Us through a third party social network. To learn more about how your information from a third party social network is obtained by Wyeth, or to opt-out of sharing such social network information, please visit the website of the relevant third party social network.
Payment and Financial information. Any information that We need in order to fulfil an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). In any case, We handle payment and financial information in a manner compliant with applicable laws and regulations.
3. PERSONAL DATA OF CHILDREN
We do not knowingly solicit or collect personal data from children below the age of . However, Wyeth under certain circumstances may collect personal data about children below the age of 13 from the child's parent or guardian directly and by obtaining the explicit consent of the parent or guardian.
4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
5. USES MADE OF YOUR PERSONAL DATA
The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.
|What We collect and use your Personal Data for||Our basis and legitimate interests|
Healthcare professional engagement service. We may use your Personal Data for service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. general question, event updates and information etc.).
Sharing information and nutrition tips. We may use your Personal Data to provide you with information about science based information and nutrition tips. This can be done via means such as email, ads, SMS, phone calls and postal mailings to the extent permitted by applicable laws. Some of our campaigns and events are run on third party websites and/or social networks. This use of your Personal Data is voluntary, which means that you can opt out (or withdraw your consent in certain countries) of the processing of your Personal Data for these purposes. For detailed information on how to modify your preferences for marketing communication, please see Sections 9 and 10 below.
Third party social networks: We may use your Personal Data when you interact with third party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
Personalisation (offline and online). We may use your Personal Data (i) to analyse your preferences and habits, (ii) to anticipate your needs based on our analysis of your profile, (iii) to improve and personalise your experience on our Websites and apps; (iv) to ensure that content from our Websites/apps is optimised for you and for your computer or device; (v) to provide you with targeted advertising and content, and (vi) to allow you to participate in interactive features, when you choose to do so. For example, We remember your login ID/email address or screen name so that you can quickly login the next time you visit our site or so that you can easily retrieve the items you previously placed in your shopping cart. Based on this type of information, and with your consent (where required), We also show you specific Wyeth content or promotions that are tailored to your interests. The use of your Personal Data is voluntary, which means that you can opt out of the processing of your Personal Data for this purpose. For detailed information on how to opt-out please refer to Section 10 below.
Legal reasons or merger/acquisition. In the event that Wyeth or its assets are acquired by, or merged with, another company including through bankruptcy, We will share your Personal Data with our legal successors where permitted to do so by law. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) pursuant to an order of a competent court or tribunal ; (iii) in response to a request from a competent government agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement, notice or the terms of any Website or app.
6. DISCLOSURE OF YOUR PERSONAL DATA
In addition to the members of the Wyeth group of companies, We may share your Personal Data with the following types of third party organisations:
Service providers. These are external companies that We use to help Us run our business (e.g. order fulfilment, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, website development, data analysis, CRC, etc.). Service providers are only allowed to access and use your Personal Data on our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required by contract to keep your Personal Data secure in accordance with applicable laws.
Credit reporting agencies/debt collectors. To the extent permitted by applicable law, credit reporting agencies and debt collectors are external companies that We use to help Us to verify your creditworthiness (in particular for orders with invoice) or to collect outstanding invoices.
Third party companies using Personal Data for their own marketing purposes. Except in situations where you have given your consent, We do not license or sell your Personal Data to third party companies for their own marketing purposes. Their identity will be disclosed at the time your consent is sought.
Third party recipients using Personal Data for legal reasons or due to merger/acquisition. We may disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger (see Section 5 for details).
7. RETENTION OF YOUR PERSONAL DATA
In accordance with applicable laws, We will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected (as described in Section 5 above) or where such use is necessary for legal or business purposes.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
We use appropriate measures (described below) to keep your Personal Data confidential and secure.
People who can access your Personal Data. Your Personal Data will be processed by our authorised staff or agents, for the specific purposes for which your Personal Data has been collected.
Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although We will do our best to protect your Personal Data, We cannot guarantee the security of any data during transmission through our Websites/apps.
Measures We expect you to take. It is important that you also play a role in keeping your Personal Data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls We provide you in our Website/app.
Transfer of your Personal Data. We may need to transfer your Personal Data between members of the Nestlé and Wyeth group of companies, and to third parties as noted in Section 6 above, in connection with the purposes set out in this Privacy Notice. For this reason, We may transfer your Personal Data to other countries that have different laws and data protection compliance requirements from those that apply in Singapore.
9. YOUR RIGHTS
Access to Personal Data. You have the right to access, review and request a copy of the Personal Data We hold about you subject to certain exceptions.
These rights can be exercised by sending Us an e-mail Nestle.Privacy@SG.nestle.com. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to Us will only be processed in accordance with, and to the extent permitted by applicable laws.
Additional rights (e.g. modification, deletion of Personal Data). Where mandated by applicable law, you can (i) request deletion, portability, correction or revision of your Personal Data; (ii) limit the use and disclosure of your Personal Data; and (iii) revoke consent to any of our processing activities.
Please note that, in certain circumstances, We will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our legal and business needs.
Where available, our Websites have a dedicated feature through which you can review and update the Personal Data that you have provided. Please note that We require our registered consumers to verify their identity (e.g. login ID/email address, password) before they can access or make changes to their account information. This helps prevent unauthorised access to your account.
10. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We strive to provide you with choices regarding the Personal Data that you provide to Us. The following mechanisms give you the following control over your Personal Data:
Cookies/Similar Technologies. You manage your consent via (i) (where available) our consent management solution or (ii) your browser so as to refuse all or some cookies/similar technologies, or to alert you when they are being used. Please see Section 4 above.
Advertising, marketing and promotions. If you decide that you no longer wish to receive marketing or promotional communications, you can unsubscribe to marketing-related communications at any time. To unsubscribe from marketing communications sent by any medium, including third party social networks, you can opt-out at any time by selecting the options available under “My account”. For queries, please contact the Data Protection Officer at Nestlé.email@example.com
Targeted Advertising. We partner with ad networks and other providers (“Advertising Providers”) that serve advertising on behalf of Us and other non-affiliated companies on the Internet. Some of those advertisements are tailored to your interests based on information collected on Wyeth sites or on non-affiliated websites over time. You can visit www.aboutads.info/choices to learn more about this type of advertising, as well as about how to opt-out of interest-based advertising practices from companies that participate in the Digital Advertising Alliance’s (“DAA”) self-regulatory program. Additionally, you can opt-out of this type of advertising in mobile applications from companies that participate in the DAA’s AppChoices app by downloading the app from the iOS or Android app store. You can also stop the collection of precise location data from a mobile device by configuring your device location service settings.
11. CHANGES TO THIS NOTICE
We reserve the right to make changes to our practices and this Notice at any time, please check frequently to see any updates or changes to our Notice.
12. DATA PRIVACY CONTACT
To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please contact our Data Protection Officer via email at: Nestle.Privacy@SG.nestle.com or by post: 15A Changi Business Park Central 1, #05-02/03 Eightrium @ Changi Business Park, 486035 Singapore.