Data Protection Statement 

Henkel Jebel Ali FZCO (referred to as “Henkel”, “we” or “us”), respects the privacy of each person who visits our website (referred to as “user(s)” or “you” or “your”). Now we would like to inform you of the type of data collected by Henkel and how they are used. You will also learn how you can exercise your data subjects’ rights.

Please note any changes to this Data Protection Statement will be published on this page. This enables you to stay informed at all times time about which data we are collecting and how we use such data.

This Data Protection Statement does not apply to websites accessible via hyperlinks on Henkel websites.

Name of the responsible entity: Henkel Jebel Ali FZCO

Address of the responsible entity: Dubai Silicon Oasis, Block F, Dubai, United Arab Emirates

Henkel uses personal data primarily to provide this website to the users and to ensure the proper functioning and security of this website. Any further processing of the data only occurs on the basis of other legally justifiable legal basis as per applicable laws or if the respective user has provided consent.

When users visit the website, Henkel automatically collects and stores certain data. Henkel stores and processes the following data data for the following purposes:

• IP address or device ID allocated to the respective end-device which we need for transmitting requested content ‏(e.g. especially content, texts, and images as well as data files provided for downloading, etc.),
• The activity of users in the context of the website, the type of respective end-device, the type of browser as well as the date and time of access.

Henkel uses the above information for improvements to the service’s presentation, features and functionalities as well as general administration tasks. Henkel stores this information for a maximum of 7 days for the purpose of recognizing and pursuing misuse. Henkel deletes or anonymizes the data on use, including the IP addresses, without undue delay as soon as they are no longer needed for the above-mentioned purposes.

Legal basis for processing:

The processing and use of personal data shall be based on applicable legal basis  which justify the processing on the grounds of either ‏(1) consent of the user, ‏(2) performance of a contract; ‏(3) to comply with our legal/regulatory obligations; or ‏(4) Henkel has an overriding legitimate interest in ensuring and enhancing the functionality and error-free operation of the website and that it is tailored to the users’ needs where applicable laws permit. We will not process personal information in a manner inconsistent with the purpose for which it was collected except as permitted under applicable privacy laws.

Recipients of the collected data may include members of the responsible internal departments, other affiliated companies of Henkel, external service providers ‏(e.g. for hosting and content management, marketing agencies, other third party providers if this is necessary for the services they provide), authorities in the exercise of their respective duties and powers, for example, in the event of an official request on their part, or if this is necessary to establish, exercise or defend Henkel's rights, and current or future acquirers of Henkel companies in the event of a business transaction, such as a sale, merger or acquisition.

The information you submit may be transferred, stored, and hosted outside of the country from which you may be accessing our website.

We may transfer your personal information to other countries that have been recognised by the competent supervisory authority as having adequate levels of protection for personal information ‏(i.e., pursuant to ‘adequacy decisions’). In the absence of adequacy decisions, we will only transfer your personal information to countries which do not have data protection laws or to countries where your privacy and other fundamental rights will not be protected as extensively where we have implemented appropriate safeguards to ensure that your personal information remains protected and secure. Appropriate safeguards may include:

• Using Binding Corporate Rules ‏(BCRs), which are internal rules that apply to our group companies and set out how we handle your personal information. 
• Using Standard Contractual Clauses ‏(SCCs) approved by the competent supervisory authority, which are legal terms that bind us and the recipient to protect your personal information.

If you would like further details of how your personal information is protected when transferred from one country to another, then please email us at corporatecommunications.gcc@henkel.com
 

If we receive messages through any of our whistleblower-channels we process relevant personal data relating to persons relevant in the respective context, which we have received or collected directly from the whistleblower report or which we collect from other sources in the course of the investigation from publicly available sources or from third parties, in particular from witnesses or other companies within the Henkel Group.

Depending on the exact nature of the reported behavior, such data may be, e.g.:

• Contact data, in particular postal address, electronic addresses ‏(e.g., email address), telephone numbers and user IDs;
• Bank data, in particular account number, financial institute, credit card number, debit card number
• Assessment data, in particular data with regard to assessments of performance and/or potential or personality, e.g., data in connection with Henkel’s employee appraisal process;
• Learning data, in particular data about participation in training or eLearnings;
• Communication data, in particular content of electronic communication, e.g., via email or other collaboration tools;
• Connection data, in particular data that describes the circumstances of telecommunications or electronic communications, data from web analysis tools, e.g., telephone invoices, log files as well as websites, IP addresses and other data necessary for virus-scanning and cyber-defense;
• Data concerning personal life, in particular data about relatives, interests as well as data about private life ‏(which is not health data or data on religious belief)
• ID data, in particular data that is generally stated on an identity card or a driving license, e.g., the birthday or passport number;
• Pictures/Video Recording, in particular photographs as well as images from video surveillance;
  Time stamps, in particular personalized records of activities with time stamps (time events), e.g. logging of events in computer systems, safety systems or recording of working hours; and/orTransaction data, in particular data on particular contracts or legal relationships, payments, deliveries or other details of business transactions.

We will process the data specified above for the whistleblower process and the respective investigation in accordance with all relevant and applicable statutory provisions, in particular, as the case may be, data protection, whistleblowing and employment related laws on the basis of fulfillment of contract ‏(in particular employment and supply contracts), fulfillment of legal/regulatory obligations and our legitimate interests ‏(where permitted by applicable laws) such legitimate interests may be e.g.: asserting or defending against any legal claims and litigation, IT security measures, prevention and detection of criminal offences, video surveillance to safeguard domiciliary rights and the collection of evidence in the event of, e.g. any burglaries, sabotage and thefts, measures for building and plant safety ‏(e.g. physical access control), measures to secure domiciliary rights.

To the extent that we process special categories of personal data, we will generally do so on the basis of your consent ‏(save for limited instances where processing is permitted under applicable laws).

There is no obligation to provide personal data. Henkel offers ways for whistleblowers to provide information anonymously.

We will store and process data for as long as this is necessary for the respective purpose for which it is being processed ‏(e.g. for the duration of the employment relationship). Subsequently, the data will be deleted. We will delete data, which we process on the basis of legitimate interests ‏(where applicable law permits), already as soon as your interests or fundamental rights and fundamental freedoms that require the protection of personal data outweigh our legitimate interests or those of a third party, or if our legitimate interests or those of a third party no longer exist.

However, in certain cases, we will continue to store and process the data as long as we are legally obliged to retain and store this information ‏(for example, for tax or labor law reasons), as long as this is necessary to assert, exercise or defend legal rights or if we have legal grounds allowing further processing.

Within Henkel, data will only be provided to such employees ‏(for example, specialist departments required for the investigation) who need them in connection with their official duties for the above-mentioned purposes.

In addition, data may be passed on to other companies within the Henkel Group if necessary.

We may use external service providers bound by data processing agreements for the provision of required services ‏(e.g. IT services, consulting).

To the extent that this is required and permitted by data protection law, we may also pass on data to other recipients outside the Henkel Group. Such recipients may be e.g.: banks, social insurance carriers, public bodies and institutions ‏(e.g. law enforcement authorities), lawyers, tax advisors and courts.

In this context, data may also be transmitted to countries outside the UAE/KSA, in particular to other Henkel Group companies. If data is transmitted to countries outside the UAE/KSA , this will only be done in accordance with appropriate safeguards under applicable privacy laws in relation to any  international transfers.

At any time, you may assert the right to access your data. Additionally, provided that the respective requirements are met, you may assert the following rights:

• Right to information relating to your personal data being processed by us ‏(commonly known as a “data subject information request”).
• Right to request transfer of the personal data we hold about you to another controller if it is technically feasible.
• Request correction of the personal data that we hold about you. We want to make sure that your personal data is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
• Right to erasure of your personal data. In some circumstances you can ask us to delete your data. Note, however, that we may not always be able to comply with your erasure request and if that is the case, we will notify you of the specific legal reasons for our inability comply at the time of your request.
• Right to restriction of processing of your personal data where you object to the accuracy of your personal data and want to restrict processing for a specific period to allow us to verify the accuracy of the data. You may also restrict processing if you feel that the processing is in violation of the agreed upon purpose or if the processing is carried out in violation of applicable law.
• Right to object to processing of your personal data where we are relying on a legitimate interest ‏(or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes, for conducting statistical analysis that is not related to the protection of public interest, or the processing is performed in violation of the processing controls outlined under applicable law.
• Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Right to lodge a complaint with the respectively competent data protection supervisory authority.
   

Your personal information will be kept secure in accordance with good IT industry practice and the requirements of applicable privacy laws and stored securely on our IT systems and those of third parties.

If you have any questions about this statement or about the use of your personal data or you want to exercise your privacy rights, please contact us or our data protection officer, Mr. Frank  Liebich,  in the following ways:

Mr. Frank Liebich, Henkel AG & Co. KGaA, Henkelstrasse 67, D 40191 Düsseldorf, Germany (Email: Datenschutz@henkel.com).