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PRIVACY POLICY


TABLE OF CONTENTS

 * Global Privacy Policy
 * North America Supplemental Privacy Policy
 * California Privacy Policy Notice"
 * Nevada Privacy Policy Notice"


GLOBAL PRIVACY POLICY

Revised : June 16, 2021

(“Essity” or "we" or "us") takes data privacy seriously. This Privacy Policy
describes how Essity as controller within the meaning of the General Data
Protection Regulation ("GDPR") collects and processes the personal data and
other information of the users.

1. Categories of personal data and processing purposes

Metadata

You may use our website or app without providing any personal data about you. In
this case, Essity will collect only the following metadata that result from your
usage: 

Referral page, data and time of access, data volume transmitted, status of
transmission, type of web browser, IP-address, operating system and interface,
language and version of browser software.

Your IP-address will be used to enable your access to our website or app. Once
the IP-address is no longer necessary for this purpose, we will shorten your
IP-address by removing the last octet of your IP-address. The metadata,
including the shortened IP-address will be used to improve the quality and
services of our website or app by analyzing the usage behavior of our users.

Account

If you create an account on/in our website or app, you may be asked to provide
personal data about you, for example: Name, postal address, email address,
selected password, telephone number, bank account details, credit card details,
invoicing and delivery address, interests in certain products/services
(voluntary), request to receive marketing emails (voluntary). Essity processes
such personal data for purposes of providing our services to you, to provide you
with marketing materials to the extent permitted by applicable law, and to
analyze your interests for marketing purposes.

Product Orders

If you order a product via our website or app, Essity collects and processes the
following personal data about you: Your account data, type and amount of
product, purchase price, order date, order status, product returns, customer
care requests. Essity processes such personal data for purposes of carrying out
the contractual relationship and the product order, providing customer care
services, compliance with legal obligations, defending, establishing, and
exercising legal claims, and tailored marketing.

Sweepstakes:

If you participate in a sweepstake, Essity collects and processes the following
personal data about you: Name, postal address, email address, date of entry,
selection as winner, prize, answer to quiz. Essity processes such personal data
for purposes of carrying out the sweepstake, informing the winner, delivering
the price to the winner, carrying out the event, and marketing. 

Health Data: By ordering some products, Essity may collect and process also
information about health conditions as implied by product order. Health data are
sensitive data within the meaning of the GDPR and Essity is taking all necessary
steps to protect such sensitive data as legally required. Subject to consent,
Essity collects and processes health data solely for the purposes of carrying
out the contractual relationship and the product order, providing customer care
services, compliance with legal obligations, defending, establishing, and
exercising legal claims, and tailored marketing. 

2. Third Parties

 * Transfer to service providers
   

Essity may engage external service providers, who act as a data processor of
Essity, to provide certain services to Essity, such as website service
providers, marketing service providers or IT support service providers. When
providing such services, the external service providers may have access to
and/or may process your personal data.

We request those external service providers to implement and apply security
safeguards to ensure the privacy and security of your personal data.

 * Other recipients

Essity may transfer - in compliance with applicable data protection law -
personal data to law enforcement agencies, governmental authorities, legal
counsel, external consultants, or business partners. In case of a corporate
merger or acquisition, personal data may be transferred to the third parties
being involve in the merger or acquisition.

 * International transfers of Personal Data

The Personal Data that we collect or receive about you may be transferred to and
processed by recipients which are located inside or outside the European
Economic Area ("EEA"). The countries include those listed at
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
which provide an adequate level of data protection from a European data
protection law perspective. Other recipients might be located in other countries
which do not adduce an adequate level of protection from a European data
protection law perspective. Essity will take all necessary measures to ensure
that transfers out of the EEA are adequately protected as required by applicable
data protection law. With respect to transfers to countries not providing an
adequate level of data protection, we base the transfer on appropriate
safeguards, such as standard data protection clauses adopted by the European
Commission or by a supervisory authority, approved code of conducts together
with binding and enforceable commitments of the recipient, or approved
certification mechanisms together with binding and enforceable commitments of
the recipient. You can ask for a copy of the such appropriate safeguards by
contacting us as set out in Sec. 7 (Contact us) below.

3. Legal basis for the processing

We may carry out the processing of your personal data on the following legal
basis:

 * You have given your consent to the processing of your data for one or more
   specific purposes;
 * The processing is necessary for the performance of a contract to which you
   are a party or to take steps at your request prior to entering a contract;
 * The processing is necessary for compliance with a legal obligation to which
   we are subject to;
 * The processing is necessary to protect your vital interests of you or of
   another natural person;
 * The processing is necessary for the performance of a task carried out in the
   public interest or in the exercise of official authority vested in us;
 * The processing is necessary for the purposes of the legitimate interests
   pursued by us or by a third party, except where such interests are overridden
   by the interests or fundamental rights and freedoms of you which require
   protection of personal data, in particular if you are a child;
 * Other applicable legal basis for data processing, especially provisions set
   out by member state law;

We may carry out the processing of your sensitive personal data on the following
legal basis:

 * You have given your explicit consent to the processing of your sensitive
   personal data for one or more specific purposes;
 * The processing is necessary for the purposes of carrying out the obligations
   and exercising specific rights of Essity or of the data subject in the field
   of employment and social security and social protection law;
 * The processing relates to personal data which are manifestly made public by
   the data subject;
 * The processing is necessary for the establishment, exercise or defense of
   legal claims or whenever courts are acting in their judicial capacity;

The provision of your personal data is required by a statutory or contractual
obligation, or necessary to enter into a contract with us or to receive our
services/products as requested by you, or simply voluntary for you.

Not providing your personal data may result in disadvantages for you, e.g. you
may not be able to receive certain products and services. However, unless
otherwise specified, not providing your personal data will not result in legal
consequences for you.

4. What rights do you have and how can you assert your rights?

If you have declared your consent regarding certain collecting, processing and
use of your personal data, you can revoke this consent at any time with future
effect. Further, you can object to the use of your personal data for the
purposes of marketing without incurring any costs other than the transmission
costs in accordance with the basic tariffs.

Pursuant to the applicable data protection law you have the right (i) to request
access to your personal data, (ii) to request rectification of your personal
data, (iii) to request erasure of your personal data, (iv) to request
restriction of processing of your personal data, (v) to request data
portability, (vi) to object to the processing of your personal Data (including
objection to profiling), and (vii) to object to automated decision making
(including profiling).

To exercise your rights please contact us as stated under Sec. 7 (Contact us)
below.

In case of complaints you also have the right to lodge a complaint with the
competent data protection supervisory authority.

5. Cookies and other tracking technologies

This website or app uses cookies. For further information please visit our
Cookie Policy

6. How long do we keep your Personal Data?

Your personal data will be retained as long as necessary to provide you with the
services and products requested. Once our relationship has come to an end, we
will either delete your personal data or anonymize your personal data, unless
statutory retention requirements apply (such as for taxation purposes). We may
retain your contact details and interests in our products or services for a long
period of time if Essity is allowed to send you marketing materials. Also, we
may be required by applicable law to retain certain of your personal data for a
period of 10 years after the relevant taxation year. We may also retain your
personal data after the termination of the contractual relationship if your
personal data are necessary to comply with other applicable laws or if we need
your personal data to establish, exercise or defend a legal claim, on a need to
know basis only. To the extent possible, we will restrict the processing of your
personal data for such limited purposes after the termination of the contractual
relationship.

7. Contact us

If you want to exercise your data subject rights or if you have any other
questions concerning this Privacy Policy, please submit/email your request to:

dataprivacy@essity.com

Essity Aktiebolag (publ), Compliance & Ethics Team, P.O. Box 200, SE-101 23
Stockholm, Sweden

--------------------------------------------------------------------------------


NORTH AMERICAN SUPPLEMENTAL PRIVACY POLICY

This Supplemental Privacy Policy forms part of the Global Privacy Policy which
can be accessed here.  If you are a resident of the United States or Canada
these additional terms apply to you.  The Global Privacy Policy and this
Supplemental Privacy Policy are collectively referred to herein as the “Privacy
Policy.”

We reserve the right to update or modify this Privacy Policy at any time.  We
will notify you of any changes by, at a minimum, posting the updated Privacy
Policy here.  Please review this Privacy Policy periodically, and especially
before you provide any information.

Residents of California and Nevada in the United States have additional rights
under applicable laws. If you are a resident of California, click here. If you
are a resident of Nevada, click here.

As the Essity companies operate globally, we may share your personal information
among the Essity companies worldwide for the purposes described in this Privacy
Policy.

This Privacy Policy does not apply to information that health care facilities or
health care providers provide to us about their patients and residents. Health
care facilities and providers determine the type of information that is
collected, processed, transferred, and stored through their use of the Service,
and we simply process the information on their behalf to provide requested
products or services. We will retain any personal information collected for as
long as necessary to provide our products and services or as required to comply
with legal obligations, resolve disputes, and enforce any agreements.   If you
are a resident of a health care facility or patient of a health care provider,
the facility or provider collects and processes your information in accordance
with the facility’s or provider’s own privacy policy. You should contact the
facility or provider for more information about its privacy practices. If you
would like to access, update, or delete your information, you should contact the
facility or provider, and we will respond to any such request they transmit to
us as required by applicable laws.

The Service may contain links to other websites not owned by us and other
websites not owned by us may reference or link to our Service. We encourage our
users to read the privacy policies of each website they interact with. We do not
endorse, screen or approve, and are not responsible for the privacy practices or
content of other websites that we do not own. Visiting these other websites is
at your own risk.

The Service may also contain links and interactive features with various social
media platforms. If you already use these platforms, their cookies may be set on
your device when using our Service. You should be aware that personal
information you voluntarily include and transmit online in a publicly accessible
blog, chat room, social media platform or otherwise online, or that you share in
an open forum may be viewed and used by others without any restrictions. We are
unable to control such uses of your information when interacting with a social
media platform, and by using such services you assume the risk that the personal
information provided by you may be viewed and used by third parties for any
number of purposes.


The Service may also contain pixels to track behavior on site, identified by
users IP addresses, for the purpose of delivering content and promotions catered
to the users interests.

The data collected will NOT be shared or sold to any outside organizations, and
will NOT track user activity outside of the TENA website.

We implement reasonable physical, administrative, and technical security
measures to protect your personal information. While we take reasonable measures
to protect the information we collect via the Services against loss, theft and
unauthorized access, use, disclosure, or modification, we cannot guarantee its
absolute security. No Internet, email, or mobile application transmission or
database is ever fully secure or error free. You should use caution whenever
submitting or sharing information through the Service. Please keep your account
password confidential to help ensure the security of your personal information.


CALIFORNIA PRIVACY NOTICE

If you are a California resident, the California Consumer Privacy Act of 2018
(“CCPA”) provides you with certain rights with regard to your personal
information. This Privacy Notice describes how we collect, use, sell or disclose
personal information of residents of the State of California, either online or
offline.

The term “personal information” is defined in the CCPA as information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer or household. Personal information does not include publicly available
information obtained from government records or deidentified or aggregated
consumer information that cannot be reconstructed to identify you.

Personal Information We Collect

During the preceding 12 months, we have collected the following categories of
personal information:




Category of Personal Information Examples Identifiers  IP address Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e)) None Characteristics of protected classifications under
federal and California law None Commercial information Records of products or
services purchased, obtained, or considered Biometric information  None Internet
or other electronic network activity information Device information, browser
type, operating system, browsing history, search history, and information
regarding a user’s interaction with our website or an advertisement Sensory
data  None Professional or employment-related information Household or lifestyle
information, interests, tastes, and preferences  Other information you choose to
provide  Photos, videos, and other content and information you provide through
the services or in communications with us


Sources of Personal Information

We collect personal information about you (1) directly from you when you provide
it to us, (2) automatically using cookies and other tracking technologies when
you use our website and mobile applications, and (3) from third parties.

Business or Commercial Purposes for Collecting Personal Information

We use and process the personal information we collect to:

 * Facilitate our provision of, and your use, of the Service;
 * Develop and improve our products and services;
 * Process and respond to your inquiries and requests;
 * Provide products and services you request;
 * Identify you as a user of the Service;
 * Contact and communicate with you, including for marketing purposes;
 * Conduct promotions;
 * Perform analytics;
 * Display relevant advertising;
 * Prevent fraudulent transactions and prevent misuse of the Service, monitor
   against theft, protect our intellectual property or the rights or property of
   others, and otherwise protect our users and our business; and
 * Comply with legal obligations and defend, establish and exercise legal
   claims.

We may combine any of the information we collect from or about you and use it in
the manner described in this Privacy Policy.

Disclosure and Sale of Personal Information

We share your personal information with other parties as described in the Global
Privacy Policy. We may engage in the “sale” of your personal information, as
that term is defined in the CCPA. For more information about the circumstances
in which we may sell your personal information and your right to opt-out, see
the Right to Opt-Out section below.


YOUR CALIFORNIA PRIVACY RIGHTS AND HOW TO EXERCISE THEM 

If you are a California resident, the CCPA provides you with the following
rights with respect to your personal information:

 * Right to Know. You have a right to request that we disclose, no more than
   twice in a 12-month period:
   * The categories and specific pieces of personal information we have
     collected about you.
   * The categories and sources from which personal information is collected.
   * The business or commercial purposes for collecting or selling personal
     information.
   * The categories of third parties with whom we share personal information.

We will provide this information upon receipt of a verifiable consumer request.
How we will verify your identity depends on how you have interacted with us in
the past. To exercise this right, you can contact us by phone at 1-866-722-6659
or by email at dataprivacy@essity.com. 

 * Right to Delete. You have a right to request that we delete personal
   information about you that we have collected from you, subject to certain
   exceptions. If we are required to delete your personal information, then upon
   receipt of a verifiable request, we will delete your personal information
   from our records and direct any service providers to delete your personal
   information from their records. To exercise this right, you can contact us by
   phone at 1-866-722-6659 or by email at dataprivacy@essity.com.
 * Right to Opt-Out. You have a right to opt-out of the “sale” of your personal
   information to third parties. We share certain personal information with
   third parties under circumstances that might be deemed a “sale” under the
   CCPA, such as when we allow advertising technology partners to use cookies
   and other technologies to collect your information and present advertising
   messages based on your preferences and to help us identify other users likely
   to be interested in our products and services. For more information or to
   opt-out, you can contact us at dataprivacy@essity.com or click here.

Only you, or someone legally authorized to act on your behalf, may make a
request under the CCPA related to your personal information. Any request must
provide sufficient details so we can evaluate and respond to the request. We may
request an individual’s first and last name, email address, mailing address,
and/or other information to verify an individual’s identity. If you designate an
authorized agent, the agent will be required to submit proof of authorization
and you will be required to verify your identity. We will not discriminate
against you for exercising your rights under the CCPA. We reserve the right to
refuse any requests, in whole or in part, to the extent permitted by law.

Under California Civil Code Section 1798.83, California residents have a right
to request, once per year and free of charge, information about the categories
of personal information (if any) we have disclosed to third parties for their
direct marketing purposes during the previous calendar year. If you are a
California resident and would like to make such a request, please send an email
to dataprivacy@essity.com with the subject line “California Shine the Light
Request.”


NEVADA PRIVACY NOTICE

Nevada residents have a right to submit a verified request directing a website
operator to not make any “sale” of covered information collected about a
consumer for monetary consideration to a person for such person to license or
sell the information to additional persons, subject to certain exceptions. We do
not engage in the “sale” of covered information, as that term is defined."









THIS IS TENA

TENA is a brand of Essity, a leading global hygiene and health company. With
over 60 years of experience TENA is the No 1 adult incontinence brand globally*.
We offer a full range of absorbent products, skincare and digital health
technology solutions that are tailored to the needs of individuals, their
families and healthcare professionals.
 
With TENA, Essity is at the forefront of developing products and services that
help improve dignity and the quality of people’s lives. Our products reduce our
carbon footprint, step by step, we’re not just protecting people, but the planet
too.
 
*Euromonitor International Limited; Retail Adult Incontinence, all channels, RSP
value sales, Tissue & Hygiene, 2020 edition.
Read more about TENA


CONTACT US

Consumer
1-866-ASK-TENA (1-866-275-8362)

Professional
1-866-722-6659

 
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