Privacy Policy

1. Ownership of the website

This WEBSITE is published by ARJOWIGGINS SCOTLAND LIMITED, a company
incorporated under the laws of Scotland, whose registered office is located at Johnstone House, 52-54
Rose Street, Aberdeen, Scotland AB10 1HA, company registration number SC634249 (‘ARJOWIGGINS’),
Intra-Community VAT number: GB332003171

The head of publication and person responsible for this WEBSITE is Mr. Jonathan Mitchell.

ARJOWIGGINS may be contacted by telephone on +00 44(0) 1256 728 763 or by e-mail at

This WEBSITE is hosted by CloudSpace, a company incorporated under the laws of England and Wales under
the registered number 05128948, whose registered office is located at Lullingstone House, 5 Castle
Street, Canterbury, Kent, CT1 2FG, United Kingdom, and who may be contacted by telephone on +44 (0) 207
043 0667 or by e-mail at

2. Personal Data Protection

2.1 Main Definition

Throughout this Privacy Policy:

The term “User” shall mean an Internet user who accesses and uses the WEBSITE.
The term “Personal Data” shall mean any information, whatever the form thereof, which can be used to
directly or indirectly identify the natural persons to which it relates.
In France, personal data is protected by:

Regulation (UE) 2016/679 of the European Parliament and of the Council date 27 April 2016, and
Any related local law applicable as the Data Protection Act 2018 in the United Kingdom and its
successive amendments on information technology, data files and civil liberties.
All of the foregoing called the “Personal Data Protection Laws”.
Any other term with capital letter not hereinafter defined shall have the same meaning as defined in the
Personal Data Protection Laws.

2.2 Data Controller

Personal Data gathered through this WEBSITE are processed manually and electronically in accordance to
Personal Data Protection Laws by ARJOWIGGINS that acts as the Data Controller.

Data processing is based on the Data Subject consent and/or on the need for ARJOWIGGINS to enter,
perform, terminate or enforce a contract with the Data Subject and/or to comply with legal obligations
and/or to achieve a legitimate interest.

ARJOWIGGINS declares the Lead Supervisory Authority competent to settle any claim related to its
processing of Personal Data shall be Information Commissioner’s Office of the United Kingdom.

2.3 Personal Data Collected

Personal Data collected and processed are identity and contact details that include:

First Name and Last Name
Email address
If the User has subscribed or not to receiving information from ARJOWIGGINS

The Users shall provide this information in a fully informed manner, for instance when keying it in
themselves in the User form available on the WEBSITE. By creating an account, the User agrees to the
Terms and Conditions and Privacy Policy of the website.

2.4 Purpose of Personal Data Collected

ARJOWIGGINS shall only collect personal data for the purposes of performing services offered by the
through the WEBSITE:

Specific purpose: E-mailing

If the User has agreed to receive information from ARJOWIGGINS, Arjowiggins will be then allowed to send
him digital or printed marketing/commercial information, such as product information, commercial offer,
information about an event, information about a project, or an invitation, for example.

In order to unsubscribe, the User can click on the unsubscribe link which will be included under any
email sent by Arjowiggins, or send an email to

2.5 Authorized Recipient

Personal Data is disclosed by ARJOWIGGINS i) where this is necessary for the stated purposes, within its
own organization and/or its subsidiary companies, its service providers and its official distributors in
any relevant country, which are located around the world, in every country where ARJOWIGGINS group
operates (for more information regarding these countries: click here); (ii) if required by applicable
law; (iii) in connection with a reorganization or combination of ARJOWIGGINS with another company, (iv)
if ARJOWIGGINS believes that such disclosure is necessary to enforce or apply terms of contract and
other agreements or otherwise protect and defend ARJOWIGGINS’s rights, property or safety; (v) in order
to comply with a judicial proceeding, court order or other legal obligation, or a regulatory or
government inquiry; or (vi) with your consent.

In particular, the Personal Data will be stored and/or supported by the authorized recipient listed as

CloudSpace, our WEBSITE hoster located in the UK, a company incorporated under the laws of England and
Wales under the registered number 05128948, Registered Office: Lullingstone House, 5 Castle Street,
Canterbury, Kent, CT1 2FG, United Kingdom

THINK SYSTEMS, our website development agency located in the UK who has access to this website to ensure
technical support and development (Registered in XXX)

ARJOWIGGINS’ official distributors (click here to access the list) for follow up of the orders and for
providing User with marketing/commercial information or offer on our products and services.

We require all authorized recipient to comply with Personal Data Protection Laws and to use Personal
Data only for the specified purposes, in accordance with our instructions and with appropriate
organizational and technical security measures, subject to the execution of a Data processing agreement
each time required. When those recipients are located in a country that does not provide an adequate
level of protection in the meaning of the Personal Data Protection Laws, and in order to transfer
personal data in a secure way, in accordance with applicable Personal Data Protection Laws, the
so-called Standard Contractual Clauses are executed to ensure appropriate security measures are
implemented for the processing of the Personal Data.

2.6 Data Retention

Personal data will be kept for a minimum period of 2 years and might be kept for an extra-period defined
by the applicable statute of limitation.

2.7 Right to access, correct and object to the use of personal data

In accordance with the Personal Data Protection Laws, User has a right to access (free of charge),
modify, rectify, erase, block and delete any of its personal data, request an explanation and/or to
object to the processing of its Personal Data for legitimate reasons. Finally, User can send “special
directives” regarding the use of its data after its death. To exercise these rights, a request shall be
sent to the following address:

2.8 Data Security

ARJOWIGGINS undertakes to ensure appropriate measures to preserve the security and confidentiality of
Users’ personal data, and to prevent them from being distorted, damaged, destroyed or accessible by
unauthorized third parties. The personal data provided by Users are stored on secure servers (protection
by username and password, and firewall), especially on the server of the WEBSITE Hoster. In addition,
access to Personal Data is limited to those employees, agents, contractors and other third parties who
have a need to know, that will only process Personal Data on instructions and are subject to a duty of
confidentiality. Procedures to deal with any suspected Personal Data breach are in place, and
notification to Data Subject or and any relevant regulator of a breach will be performed where legally
required to do so.

However, the transfer of personal data on the Internet presents intrinsic risks that ARJOWIGGINS cannot
totally prevent with regard to the security of the data thus sent. Therefore, ARJOWIGGINS warns Users
about the potential risks involved in the operation and use of this WEBSITE, and so for Users to take
the necessary measures of protection in the management of their navigation on the Internet (like using
updated hardware and software, up-to-date anti-virus, confidentiality measures to protect identifiers
and password, etc.).

2.9 Third Party Links

This WEBSITE may include links to third-party websites, plug-ins and applications (hereinafter
“Third-party Links”). Clicking on those links or enabling those connections may allow third parties to
collect or share personal data of User.

The management and security of the personal data provided by Users on any Third-party Links, are under
the sole responsibility of the respective publisher of said Third-party Links. These Third-party Links
include, but are not limited to, the following ones:

Any other Third-party Links such as those of the third-party cookies publishers identified in the Cookie
Policy of this WEBSITE.

ARJOWIGGINS is NOT the Data Controller for any of these Third-party Links as it does not control the
processing of the personal data provided directly by the Users through these Third-party Links, and
CANNOT in anyway guarantee the security of the data sent by Users. Users must be aware of the Privacy
Policy available on these Third-party Links.