Crayola Privacy Policy Addendum - General Data Privacy Regulation

This policy shall be an addendum to any existing Crayola Privacy Policy and shall apply only to Personal Data, as that term is defined in the GDPR that is collected or processed by Crayola LLC or its subsidiaries or affiliates (“Crayola”) within the scope and coverage of the GDPR. This addendum shall supplement or supersede any other Privacy Policy or parts thereof only to the extent that the GDPR imposes obligations on Personal Data Crayola processes or collects.

How does Crayola use Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you (for example, to process your order and provide you with an online account)
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (such as where it is necessary for the administration of our business, our legal risk management and managing the performance of our website).
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. If you withdraw your consent this will not affect the lawfulness of any processing carried out before you withdrew it.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

For what purpose will Crayola use your Personal Data?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, the types of data that may be involved, and which of the legal bases we rely on to process it. We have also identified what our legitimate interests are where appropriate.

>Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To identify and/or register you as a new customer or supplier	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

What is Crayola’s email marketing policy?

Opt in: In order to receive e-mail reminders from Crayola or to receive e-mails from Crayola regarding new services and products, you must opt in to receive communications from us. If Crayola collects personal data through a website or physical means, you will be given the opportunity to opt in to receiving any communication from us other than that required to process your registration and inform you of progress of subsequent orders.

Marketing messages will contain a link that allows you to unsubscribe from our marketing list and will opt you out of receiving e-mail marketing.

If at any point you decide to opt out we will not be able to send you any more reminders or communications about new products and services.

Will Personal Information be transferred outside the EEA?

Sometimes we may transfer your data outside the EEA, however, we will only do so where there are adequate safeguards in place. We may share information within our company headquarters in the US. The appropriate safeguards are standard contractual (controller-to-controller) model clauses, approved by the European Commission.

Will I be subject to automated decision taking or profiling?

We do not use your data for automated decision taking or profiling.

How long will Crayola retain my Personal Information for?

We will only keep your data for as long as is necessary and justified. We take steps to ensure that we only keep the minimum data we need for the purposes of our legitimate interests (in the management of our business and its risks) and in line with our legal obligations.

We will normally keep your information for a maximum of seven years. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you would like more information about how long we retain specific data, you can contact us using the details set out in this policy.

What are my Legal Rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data, including to object to direct marketing.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent

We may provide you with a standard form to help you specify your request. You are not required to use the standard form we provide, but it may be helpful and save time if you do.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests as soon as possible and in any event within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In such cases it may take up to two further months to process your request.