SPB Mediacenter Privacy Policy

We take data protection and confidentiality extremely seriously and comply with national and European data protection regulations. We therefore want to explain the most important aspects with regard to the collection, processing and use of data, particularly which information and personal data is stored and how we handle it.

1. Controller

The controller responsible for the collection, processing and use of your personal data by this website (Spectrum Brands Mediacenter) as defined by the General Data Protection Regulation is Tetra GmbH, Herrenteich 78, 49324 Melle, Germany (‘Controller’, Art. 4 (7) GDPR).

2. Collection, processing and use of personal data

2.1. Personal data

Personal data means any information relating to an identified or identifiable natural person (Art. 4 (1) GDPR).

This particularly includes your name, e-mail address, telephone number, address and date of birth as well as all inventory data that you provide us within the scope of registering a customer account (hereinafter simply referred as ‘personal data’).

Statistical data that we collect by default for technical reasons when you visit our website and which is anonymised and therefore cannot be directly linked to you does not fall under this Privacy Policy. This includes information about how often you access our website, how much time you spend on it and the pages you access as well as about browsers, IP addresses and software and hardware properties. This information is collected and processed in anonymised format in order to find out about the use of our website and accordingly optimise it.

2.2. Collection, processing and use of your data

We collect and process the following categories of personal data for the following purposes:

2.2.1. Registration and provision of services

We collect and process the following data when you apply to access the Spectrum Brands Mediacenter (registration):

  • Company name
  • Customer number (where applicable)
  • Address (street, number, postcode, town/city)
  • Country of registered office
  • Full name of the contact person
  • E-mail address of the contact person
  • Telephone number of the contact person
  • Company website (where applicable)
  • Company’s commercial register number
  • Password

This data is used to review and process your request, provide our services and for technical administration purposes.

The legal basis for processing the data is Art. 6 (1)(b) GDPR as it is required to prepare and perform contracts to which you are party.

2.2.2. Login memory

Upon successful verification of your data we create a user profile for you, in which the aforementioned data is stored and which is linked to an individual username assignable to your user profile.

The system saves your first login and most recent login using your username (login memory).

We use this login data to regularly review and clean up our database of user profiles with the aim of deactivating profiles that have never been used or have not been used for a long time (three years).

The legal basis for processing the data is Art. 6 (1)(f) GDPR as it is necessary for the purposes of the legitimate interests pursued by the controller or a third party.

2.2.3. Tracking

Your IP address will also be saved when you use the Mediacenter (tracking).

Tracking records all download processes performed via the Mediacenter. The following data is stored together with your IP address and username:

  • Timestamp: time of creation of the ZIP file for this entry
  • File ID: unique internal identification number for the respective content
  • File name: file name of the respective content

The tracking data is solely processed for evidence purposes, if this is necessary to defend against asserted claims. The legal basis for processing the data is Art. 6 (1)(f) GDPR as it is necessary for the purposes of the legitimate interests pursued by the controller or a third party.

2.3. Retention period

We will store the personal data for the duration of our business relations and beyond until expiration of the statutory maximum limitation periods (currently 30 years). The long retention period is necessary because the content provided via the Mediacenter is protected by copyright, trademark or other legal proprietary rights and such proprietary rights are valid for long and sometimes even indefinite periods. Sufficient defence against potential legal claims is not guaranteed with shorter retention periods.

Upon deactivating your profile, we will delete the data in the login memory (first and most recent logins). We check that our database is up to date at least once a year by identifying profiles that have never been used or have not been used for a long time (three years).

At this point, we delete all the profile data for profiles that have never been used (no logins or not a single download process). The same applies if your profile has already been deactivated and all tracking data has been deleted in accordance with the deletion periods outlined above.

3. How do we share your personal data with third parties?

Your personal data will only be shared with third parties in the following cases:

  • With our IT agencies that provide us with IT services and only process such data for the purpose of these services
  • With courts, arbitration bodies, law enforcement authorities, supervisory authorities and lawyers if this is necessary in order to comply with the law or to justify, exercise or defend rights or legal entitlements.

If we commission other companies to perform tasks on our behalf within the scope of an order processing agreement and disclose your personal data to this end, these companies are obligated to protect your personal data and only use it for the purposes established in the agreements entered into with them.

In cases where we transmit personal data to countries outside the EU/EEA, we only do so to external recipients in these countries if they have taken sufficient security precautions in line with legal requirements, such as agreeing to standard EU contractual clauses or holding Privacy Shield certification.

You can request further information, such as copies of the security precautions for the individual transmission operations, by contacting dsr@eu.spectrumbrands.com.

4. Your rights in relation to your personal data

Subject to the fulfilment of certain conditions, you have the following rights:

  • The right to information about your personal information that we process
  • The right to the rectification of your personal data
  • The right to the deletion of your personal data
  • The right to restrict the processing of your personal data
  • The right to object to the processing of your personal data
  • The right to receive your personal data in a structured, commonly used and machine-readable format (right to data portability)
  • The right to withdraw your consent to use your personal data with future effect
  • The right not to be subject to a decision based solely on automated processing, including profiling

You can exercise your rights using the following contact details:

Tetra GmbH
DSR Request
Herrenteich 78
49324 Melle
Phone +49 (0) 54 22 / 1 05 0
Fax +49 (0) 54 22 / 4 29 85

We will respond to your request in accordance with current legal provisions.

5. Cookies

Click here to find out more about our Cookie Policy.

6. Data security

We endeavour to use all technical and organisational possibilities to store your data in a way that it is inaccessible for third parties.

All data is stored on servers which are operated to high security standards and protected against access by unauthorised persons and misuse.

7. Data protection officer

If you have any questions about this Privacy Policy or the processing of your personal data, please contact our data protection officer:

Data protection officer
Herrenteich 78
49324 Melle

8. Your right to lodge a complaint with a supervisory authority

If you believe that our processing of your personal data is in breach of data protection laws, you have the right to lodge a complaint with the relevant supervisory authority.

© Tetra GmbH, October 2018