Privacy policies

PERSONAL DATA PROCESSING POLICY OF SPECTRUM BRANDS DE MEXICO, S.A. DE C.V. Spectrum Brands de Mexico, S.A. de C.V. (hereinafter “the Company” or “Spectrum Brands”) is a company specialized in (1) the purchase, sale, manufacture, marketing, import and export of leather, fishing and agricultural products and by-products; (2) the manufacture, import, export, and internal commercialization, agency, distribution, purchase and sale at wholesale and retail of medical devices and biomedical equipment, as well as all kinds of electronic or electrical household appliances for personal use, including different parts, components and spare parts; (3) The manufacture, import, export, internal marketing, agency, distribution, purchase and sale at wholesale and retail of disposable razors, as well as all kinds of products for personal use and human hygiene; (4) The manufacture, import, export, internal marketing, agency, distribution, purchase and sale at wholesale and retail of all kinds of repellents, fungicides, pesticides, insecticides and fertilizers; (5) The manufacture, import, export, internal marketing, agency, distribution, purchase and sale at wholesale and retail of all kinds of pet food, as well as food for fish and amphibians, including products for use or consumption in aquariums, ponds, or any other space where fish or amphibians may reproduce; (6) The manufacture, import, export; internal commercialization, agency, distribution, purchase and sale at wholesale and retail of all kinds of goods and products for industrial use and belonging to the hardware, construction and other similar industries; (7) The rendering of professional advisory services with respect to those products it produces or commercializes; (8) The commercial representation of national or foreign firms engaged in the same, similar, related or complementary activities as those mentioned above; (9) additionally, it may engage in any other lawful economic, commercial or civil activity both in the country and abroad, including the power to give or receive loans.
In accordance with the provisions of the Applicable Law on the matter, the Company is committed to the due protection of the rights of the Holders of Personal Data, and the information provided by them.
This Data Processing Policy (the “Policy”) shall be applicable to the Processing of Personal Data that the Company collects through different means, either face-to-face and/or electronic mechanisms. In this sense, the Holders must read in advance and in detail the information contained in this Policy, since it is intended to provide the Holders of the information a clear picture regarding the personal data that the Company collects, the treatment that is given to them and the procedures available to them to enforce their rights. Being outside the needs of the Program or Platform, the Company will not collect or request Sensitive Personal Data or Personal Data of children or adolescents.
Holders are not obliged to provide Personal Data to the Company. Please refrain from providing any data or information to the Company if you do not agree with the terms of this Policy. In this case, Holders may not use the Company's Programme or Platform.
I. DEFINITIONS The terms whose first letter is capitalized (except when it is exclusively due to the fact that they start a sentence or it is a proper name), have the meaning assigned to them below:
“Authorization”: Prior, express and informed consent of the Holder to carry out the Processing of Personal Data.
“Database”: Organized set of Personal Data that is subject to processing.
“Personal Data”: Any information linked or that may be associated to one or more determined or determinable natural person(s), whether numerical, alphabetical, graphic, photographic, acoustic or of any other kind.
“Financial Data(s)”: Any Personal Data of a financial nature, such as bank account and credit card information.
“Sensitive Data”: Those Personal Data that affect the privacy of the Holder or whose improper use may generate discrimination, such as but not limited to those that reveal racial or ethnic origin, political orientation, religious, moral or philosophical convictions, membership in trade unions, participation in social organizations, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties as well as data relating to health, sex life and biometric data (in the case of the latter insofar as they reveal data that may be potentially discriminatory to the Holder).
“Data Processor”: natural or legal person, public or private, who by himself or in association with others, carries out the Processing of Personal Data on behalf of the Responsible for the Processing.
“Processor”: means a person appointed by the Data Processor and the Responsible for the Processing to act as a channel of contact between the Responsible for the Processing, the Holders and the governmental authorities of a given country, as required by the Applicable Law.
“Applicable Law”: means the set of rules applicable from time to time to the processing of Personal Data in each jurisdiction.
“Programme” or “Platform”: Means the Company's website or the channel (physical or electronic) through which the Company receives the Personal Data of the Holder.
“Responsible for the Processing”: natural or legal person, public or private, who alone or in association with others, decides on the Database and/or the Processing of the data.
“Holder”: person whose Personal Data is being subject to Processing.
“Processing”: any operation or set of operations, carried out by means of automated or manual, written or digital procedures on Personal Data, such as the collection, storage, use, circulation, deletion, conservation, ordering, modification, relation, evaluation, blocking, and in general, the processing of Personal Data, as well as their transfer to third parties through communications, consultations, interconnections or transfers, as well as any other use.
II. RESPONSIBLE FOR THE PROCESSING AND/OR USE OF PERSONAL DATA In Colombia The legal entity responsible for the Processing of the Personal Data provided by the Holders, and therefore, of the Databases in which such data is located, is Spectrum Brands Corp S.A.S., identified with Tax ID (N.I.T.) 800087297-6, and with its main address in Bogotá, whose e-mail address is privacidad@spectrumbrands.com.
In Mexico Please send the request in the terms established by the Law in its Art. 28 to 35 to Mr. MOISES MARQUEZ TREJO, responsible for our Department of Personal Data Protection, located at Avenida Primero de Mayo No. 120, Piso 7, Oficina 702, Col. San Andrés Atoto, Naucalpan de Juárez, Estado de México, C.P. 53500, México, or you may contact us directly by phone (55) 5831 7070 or via e-mail to: privacidad@spectrumbrands.com.
In Argentina The legal entity responsible for the Processing of the Personal Data provided by the Holders, and therefore, of the Databases in which such data is located, is Rayovac Argentina, S.R.L., located at Av. Del Libertador, #6810, 2nd Floor, Buenos Aires, Argentina, e-mail address privacidad@spectrumbrands.com.
In Other Countries For other countries, the legal entity responsible for the Processing of the Personal Data provided by the Holders of the Databases in which they are located, is the company Spectrum Brands Corp S.A.S, 3001 Deming Way Middleton, WI 53562, e-mail: privacidad@spectrumbrands.com.
III. ACCEPTANCE By the authorization granted by the Holder at the time of providing his/her data, the Holder expressly and unequivocally accepts the terms of this Policy in accordance with the Applicable Law. As permitted by Applicable Law, the Holder further acknowledges that his or her acceptance of the terms of this Policy is a requirement for receiving the benefits of the Programme or Platform.
IV. TREATMENT AND PURPOSE Your Personal Data and Financial Personal Data may be forwarded, transferred or stored in the country or in a different country for Processing for the purposes described below, which, if this is the case, will be carried out in accordance with all Applicable Law. By providing your Personal Data and Financial Personal Data, you authorize Spectrum Brands to process them directly or through its parent company, affiliates, subsidiaries, Processors, Agents or third parties, (including suppliers, treatment service providers and other partners) in the country or abroad even in countries without adequate Personal Data protection legislation, for the purposes outlined in this Policy and in compliance with the purpose of this Policy.
Purpose and Use of Personal Data: The purpose of the processing of your Personal Data and Financial Personal Data by the Company is as follows:
1. to identify you. 2. to register you in our systems as a member of the Program or Platform. 3. to contact you for any matter related to the Program or the Platform. 4. enable you to use mobile applications and the online chat service. 5. provide you with services, products or information that you request from us including new services or products that are related to those already contracted or purchased. 6. send you the list of eligible products and sales centers participating in the Program or the Platform. 7. provide you with your business card and any replacements or redemptions. 8. provide you with assistance with your purchases and points of sale, whereby we may determine your geographic location. 9. provide you with attention and response, cancellation and suspension of cards, statements, billings, changes or modifications to the same. 10. to perform periodic evaluations of our products and services in order to improve their quality. 11. to keep our records up to date. 12. to provide information required by governmental authorities or in compliance with applicable money/asset laundering and other regulations. 13. attend to any complaint, question or comment made by you regarding our products and/or services, the Program or Platform. 14. compliance with our legal obligations and exercise of our rights.
Additionally, your Authorization to the Processing of your Personal Data includes the following purposes: · For data mining. · To develop studies and programs that are necessary to determine consumption habits. · For demographic studies. · For internal and external marketing and analytical reports. We use aggregated, anonymized and disassociated information to create external marketing and analytics reports that we may sell to other companies for their own marketing, advertising or other similar uses inside and outside the country. These reports may be a combination of wireless and Wi-Fi location information, call and text message logs, website browsing and mobile application usage. · For training and coaching activities.
Collection Mechanisms. Personal Data and Financial Personal Data collected by Spectrum Brands may be obtained electronically or through our holding companies, affiliates, subsidiaries and Processors or authorized agents, through the following mechanisms: · Spectrum Brands websites, mobile applications and social networks. · By updating or modifying your Personal Data and/or Financial Personal Data previously registered. · Through Processors and third parties. · We may also collect information about Users' preferences or interests when accessing our websites and mobile applications. · Through the technology Cookies accepted by the Holder, which collect information in order to customize the ads that appear on our sites and mobile applications on sites owned by other companies. · Also, through the technology called Web Beacons that collect a record of the pages and advertising materials accessed.
V. USE OF PERSONAL DATA The Company does not illegitimately disclose, sell or rent to third parties the Personal Data provided by the Holders. Said Personal Data will be kept with the proper security and confidentiality conditions, and its use will be exclusively for the purposes for which it was provided. In this sense, the Company will only provide this information to the persons established in the Law, and under the conditions established under the Applicable Law In the event that the Personal Data requested is suitable to be transferred to third parties, such transfer shall be made on the basis of the prior, express and written authorization given by the Holder, by means of which the transfer of the personal information provided shall be authorized.
The Company may transfer, or assign the information collected in the event of a sale, merger, consolidation, change in corporate control, substantial transfer of assets, and/or reorganization or liquidation of the Company.
VI. AUTHORIZATION The processing of Personal Data by the Company will be carried out subsequently and based on the authorization granted by the Holder of the information. In the terms set out in this Policy, such authorization shall empower the Company to collect and be Responsible for the Processing of the information provided by the Holders.
VII. RIGHTS OF THE DATA HOLDERS In accordance with the provisions of the Law, the Holders of the information shall have the following rights: a) Obtain all information about himself/herself contained in the Company's databases, which shall be provided in a clear and uncoded form, and shall be accompanied by an explanation of the terms used. b) To acknowledge, update and rectify all their Personal Data contained in the Company's database and, in the event of discrimination, inaccuracy or error, to demand the suspension, rectification and updating of such data, in accordance with the Applicable Law. c) To request proof of the authorization granted to the Company for the processing of his/her Personal Data. d) To be informed by the Company, upon written request, regarding the use it has made of their Personal Data. e) To file complaints before the competent authorities in each jurisdiction for violations of the provisions of the Law and other rules that modify and / or complement them. f) To revoke the authorization and/or request the deletion of their Personal Data (without retroactive effect), when the treatment does not respect the principles, rights and constitutional and legal guarantees. g) To be informed by the Company, upon written request, of the existence of the Processing of their Personal Data. h) To be allowed to rectify, modify, delete, supplement, include, update or cancel their Personal Data. i) To be informed by the Company, upon written request, of the public and/or private legal entities with which the Company shares or has shared their Personal Data. j) Be informed by the Company, upon written request, about the possibility of not granting the Authorization and the consequences of such refusal. k) Access free of charge to their personal data that have been processed.
VIII. PETITIONS AND CONSULTATIONS The Holders, its proxyholders, or their successors in title may consult and request access to the Personal Data contained in any of the Company's Databases, in order to exercise their rights to know, update, rectify and delete their data, and/or revoke the Authorization granted.
The consultation will be answered within a maximum term of ten (10) business days from the date of receipt of the same. When it is not possible to attend the consultation within such term, the interested party shall be informed, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first term. Without prejudice to the foregoing, in any case, the consultation shall be answered within the time limit that corresponds to the Applicable Law, whichever is shorter.
The consultation shall be formulated by the Holders or their successors in title in writing, addressed to the following e-mail address: privacidad@spectrumbrands.com. This email must specifically contain the request of the Data Holder. Once the information is received, the Company will record the date of receipt of the same and will be in charge of processing it. The consultation will be answered within a maximum term of five (5) business days from the date of receipt of the same. When it is not possible to attend the consultation within such term, the interested party shall be informed, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) business days following the expiration of the first term.
IX. CLAIMS The Data Holder, its proxyholders or its successors who consider that the information contained in a Company database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with the Company, which will be processed under the following rules: 1. The claim shall be formulated by means of a request addressed to the Company at privacidad@spectrumbrands.com with the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents to be asserted. In case of incompleteness, the Company shall request the interested party to complete the information sent within five (5) calendar days following receipt of the claim. After two (2) months from the date of the request, without the applicant submitting the required information, it shall be understood that the claim has been withdrawn.
The maximum term to address the claim will be ten (10) business days from the day following the date of receipt. When it is not possible to address the claim within such term, the interested party shall be informed of the reasons for the delay and the date on which the claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term. Without prejudice to the foregoing, in any case, the consultation shall be answered within the time limit that corresponds to the Applicable Law, whichever is shorter.
X. CONSENT Spectrum Brands makes this Policy available on its website. You acknowledge that your use and participation in the Program or Platform constitutes your acceptance of the terms of this Policy and governs your use of the Program or Platform, its benefits and our products and services. In addition to the foregoing, by registering for the Program or Platform, you acknowledge and agree that: 1. You have been made aware of this Policy. 2. You understand and agree to the terms set forth in this Policy. 3. You expressly consent to the processing of your Personal Data, Sensitive Personal Data, if applicable, and Financial Data, in accordance with this Policy. With regard to Sensitive Personal Data, we inform you that it is optional to respond to the questions that are asked with regard to this type of data, as well as the provision of such data. With regard to Sensitive Personal Data, we inform you that it is optional to answer the questions that are asked with regard to this type of data, as well as the delivery of such data.
XI. MODIFICATIONS This Policy may be modified at any time and without prior notice by the Company, for legal or institutional reasons, mediating, for such purpose, a timely communication in which the Data Holders will be notified of the modifications made by such means as the Company may deem appropriate.. In the event of a substantial modification to the purposes of the processing of Personal Data, or in terms of those responsible for it, these changes will be informed in a timely manner to the Data Holders, and prior to the implementation of the new policies, in accordance with the provisions of the Applicable Law. Each Holder will express his or her express consent, by a “click” as a sign of acceptance.
XII. CONTACT US If you have any questions or concerns about this Policy, or about the collection and processing of information by the Company, you can contact us at privacidad@spectrumbrands.com, or in other countries. Messages will be answered as soon as possible.
XIII. EFFECTIVENESS This Policy is effective as of June 2021 and until the implementation of a new version.