FISKARS GROUP SUPPLY CHAIN DUE DILIGENCE, MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2024

About Fiskars Group

Fiskars Group is the global home of design-driven brands for indoor and outdoor living. The Group is driven by its common purpose: Pioneering design to make the everyday extraordinary. Fiskars Group has a well-balanced portfolio of unique brands including Fiskars, Georg Jensen, Gerber, Iittala, Moomin Arabia, Royal Copenhagen, Waterford, and Wedgwood, as well as several smaller tactical brands. The company’s brands are present in more than 100 countries in Asia-Pacific, Europe, and the Americas.

Fiskars Group embraces the power of design in all activities, from ideation to manufacturing and business development. Through the combination of craftsmanship, brand passion and digital transformation, the Group rethinks existing solutions while always remaining loyal to brand roots.

Fiskars Group proudly upholds a longstanding commitment to ethical sourcing across its globally distributed product lines. In recent years, it has invested in mapping its supply chain to enhance transparency and continues to diligently craft and enforce ethical standards tailored to its diverse network of suppliers and distributors involved in the production, processing, and manufacturing of its product base.

The business

Fiskars Group utilizes a combination of its own manufacturing operations in connection with those of its carefully selected suppliers. Fiskars Group has 13 of its own manufacturing units located in Europe, Asia and the US. Fiskars Group has a wide network of suppliers for raw materials, components, and services. The company has built a strong network of approximately 170 finished goods suppliers that are committed to the Group’s strict standards of sustainability and human rights, product excellence and compliance with local laws.

In 2024, Fiskars Group was organized into two Business areas (BAs): Vita and Fiskars. Business Area Vita accounts for approximately 52% and Fiskars 47% of net sales. The Business areas have full accountability for the global offering, enabling them to leverage the potential of their strong brands. Both Business areas have strong, yet BA specific, business drivers.

Recognized for creative design, BA Vita consists of brands such as Georg Jensen, Royal Copenhagen, Wedgwood, Moomin Arabia and Iittala. The innovation-driven BA Fiskars’ brands include Fiskars and Gerber. It consists of the gardening and outdoor categories as well as the scissors and creating, and cooking categories.

Fiskars Group has a diverse team of close to 7,000 employees based in 29 countries.

Commitment to prevent modern slavery and human trafficking

Fiskars Group complies with all relevant labor laws and regulations in the countries where it operates, ensuring fundamental labor rights such as freedom of association and collective bargaining are respected. We are committed to eliminating forced labor, child labor, human trafficking, and discrimination in employment and occupation.

Fiskars Group is committed to adhering to the International Bill of Human Rights, UN Guiding Principles on Business and Human Rights, International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, and the United Nations Global Compact principles. The Group supports the values, freedoms, and fundamental rights promoted in these texts and is committed to continuously learning about and following the evolution of human rights.

Fiskars Group upholds zero tolerance for modern slavery and any working conditions that violate basic human rights, safeguarding vulnerable workers from exploitation, regardless of their employment contract or immigration status. To prevent these violations, Fiskars Group conducts risk assessments, performs due diligence within its operations and supply chain, and provides awareness training across its value chain.

Fiskars Group’s commitment is communicated to stakeholders through the Fiskars Group website and reinforced within the value chain via the Supplier Code of Conduct.

Governance to prevent modern slavery and human trafficking

The Fiskars Group Board of Directors holds ultimate responsibility for ensuring that human rights are respected across the company.

The Chief Executive Officer (CEO) is tasked with overseeing the implementation of these principles. Day-to-day operations regarding the identification, assessment, mitigation, prevention, monitoring, and reporting of human rights risks are managed by the company’s global functions and Business Areas.

The Internal Audit team helps Fiskars Group accomplish its business objectives by bringing a disciplined systematic approach to evaluate and improve the effectiveness of risk management, controls, and governance processes. To ensure the independence of the Internal Audit activities, VP Group Internal Audit reports administratively to the CEO and functionally to the Audit Committee.

Business Areas and Global Functions integrate the commitments and actions into their operations and respective business. BAs and Global Functions follow up on their own progress towards commitments, targets, and roadmaps.

Business conduct and policies

The Fiskars Group Code of Conduct defines and communicates the company’s commitment to conducting business in an ethical and responsible manner. The Code of Conduct applies to everyone within Fiskars Group, including employees, managers, directors, officers, board members, consultants, and other full- or part-time personnel working under Fiskars Group’s direction (referred to in this Code as “Fiskars Group People”), and covers all Fiskars Group’s companies worldwide. The Fiskars Group Employment Policy ensures that all Fiskars Group Employees, Managers and HR share a common understanding of the Group employment principles. The Policy also describes Fiskars Group’s commitment to human rights and gives guidance on global employment-related topics at Fiskars Group. The employment policy covers all employment relationships between Fiskars Group companies and Employees and is applicable across the organization globally.

The Fiskars Group Procurement & Supply Management Policy describes the principles applied in all the sourcing and purchasing activities of Fiskars Group globally. The main objective is to provide value through ethical sourcing that supports growth in a sustainable way. The policy sets the minimum standard that applies to all Fiskars Group employees and externals of the organization involved in all aspects of Fiskars Group sourcing and purchasing processes, and supplier management. The policy enables sourcing roles to control supply risk and engage with Fiskars

The Fiskars Group Procurement & Supply Management Policy describes the principles applied in all the sourcing and purchasing activities of Fiskars Group globally. The main objective is to provide value through ethical sourcing that supports growth in a sustainable way. The policy sets the minimum standard that applies to all Fiskars Group employees and externals of the organization involved in all aspects of Fiskars Group sourcing and purchasing processes, and supplier management. The policy enables sourcing roles to control supply risk and engage with Fiskars

Group’s suppliers in seeking the best supply solutions, maintain quality, and identify development needs to benefit the mutual partnership.

The Fiskars Group Supplier Code of Conduct outlines the standards all suppliers and partners must meet to do business with Fiskars Group. A new version of the Fiskars Group Supplier Code of Conduct was announced at the beginning of 2023. The new version is aligned with the latest legislation and with Fiskars Group’s updated commitments. It covers important topics such as labor and human rights, health and safety, environment, due diligence, business ethics and integrity, management systems and commitments, and the Ethics & Compliance Hotline. The Supplier Code of Conduct includes requirements on labor and human rights, including child labor, forced or involuntary labor and any form of human trafficking.

The Fiskars Group Supplier Code of Conduct outlines the standards all suppliers and partners must meet to do business with Fiskars Group. A new version of the Fiskars Group Supplier Code of Conduct was announced at the beginning of 2023. The new version is aligned with the latest legislation and with Fiskars Group’s updated commitments. It covers important topics such as labor and human rights, health and safety, environment, due diligence, business ethics and integrity, management systems and commitments, and the Ethics & Compliance Hotline. The Supplier Code of Conduct includes requirements on labor and human rights, including child labor, forced or involuntary labor and any form of human trafficking.

The Supplier Code of Conduct Process describes engagement with suppliers through site visits, annual supplier days, questionnaires, training, and an audit program.

The Supplier Code of Conduct is implemented as described in the code implementation process and monitored via audits. The implementation process describes escalation steps to be taken in case of a failed audit result.

Risks of Forced Labour or Child Labour in the Supply Chain

Fiskars Group is dedicated to maintaining a supply chain that ensures the upmost adherence to international human rights and labor standards. The company’s position in the global market provides it with a responsibility to protect and advocate for the working conditions of the people throughout its supply chain who make its products.

As part of the due diligence, Fiskars Group actively engages with its suppliers and their sub-suppliers to prevent the risk of non-compliance with the company’s human rights policies. Fiskars Group manages the effectiveness of the human rights due diligence by proactively following up on group risk management assessments and all incidents of non-compliance. Fiskars Group is proactive in reassessing processes and actions to ensure that the management system is current and effective.

The overall objective of Fiskars Group's risk management is to identify, evaluate and manage risks that may threaten the achievement of the Group's values and business goals. The most material sustainability related risks, including environmental, social and employee matters, respect for human rights, and anticorruption and bribery matters, are included in the established annual enterprise risk management process. This ensures that risks related to these areas are identified and assessed, and that control measures are set.

In 2019, Fiskars Group conducted a human rights assessment to better understand the gaps, risks, opportunities, and steps required to enhance its human rights due diligence process.

In 2023, Fiskars Group participated in the Business & Human Rights Training Program, organized by the UN Global Compact. The program provided useful tools for further developing the human rights due diligence process and supported the integration of human rights management into existing processes, annual risk management assessment, ESG strategy management and reporting.

In 2023, Fiskars Group participated in the Business & Human Rights Training Program, organized by the UN Global Compact. The program provided useful tools for further developing the human rights due diligence process and supported the integration of human rights management into existing processes, annual risk management assessment, ESG strategy management and reporting.

In 2023, the double materiality assessment (DMA) required by the Corporate Sustainability Reporting Directive (CSRD), indicated a potential significant financial risk in Fiskars Group’s upstream value chain in certain high-risk countries of sourcing. Potential risks relating to working conditions, working hours or employment conditions for migrant workers could be present due to certain sourcing activities taking place in countries with elevated risk. The potential financial risks cause Fiskars Group to deepen monitoring and prevention of potential impact. The DMA can be found in the Sustainability Statement.

In 2024, the ESG risk list of the risk assessment tool was reviewed and updated to ensure that the risk types reflect Fiskars Group’s current operational and strategic environment.

Fiskars Group Due Diligence to Prevent Forced Labor and Child Labor – creating awareness

Everyone at Fiskars Group, including leaders, employees, suppliers, partners, and community members, has a role to play in defending human rights throughout the entire value chain.

The Fiskars Group Code of Conduct and related training provide a detailed description of its approach to doing business in an ethical way. The Code of Conduct training is mandatory for all employees, and it is part of its onboarding package. Classroom training sessions are held at all Manufacturing Units and Distribution Centers in local languages at regular intervals by the local HR departments. In addition to on-boarding, everyone at Fiskars Group must complete the training every two years. The completion rate for the 2024 training is 91.6%.

Fiskars Group requires all its business partners and customers, and their subcontractors, to be governed by the same or similar principles stipulated in the Fiskars Group Code of Conduct. Fiskars Group’s Supplier Code of Conduct communicates Fiskars Group’s ethical and sustainability expectations to all its suppliers and cooperation partners.

Fiskars Group engages with its suppliers through site visits, questionnaires, training (regarding, for example, setting science-based targets) and audit program with the aim to expand awareness of the requirements in the Supplier Code of Conduct and of the topic of forced and child labor.

Fiskars Group Due Diligence to Prevent Forced Labor and Child Labor – risk management of the supply chain

Human rights and other ESG- and sustainability related topics are included in the annual ERM process, to ensure that risks related to human rights are identified and assessed, and that control measures are set up.

To manage the risks identified, firstly all suppliers and service providers to Fiskars Group are required to sign the Fiskars Group Supplier Code of Conduct prior to entering a business relationship with the company and are submitted to the Supplier Code of Conduct assessment program. New suppliers are checked in a due-diligence process prior to new vendor approval and are Supplier Code of Conduct audited prior to their approval as a supplier to Fiskars Group.

Georg Jensen is certified under the Responsible Jewellery Council (RJC), built on international standards, providing a common standard for responsible business from mine to retail, requiring third-party auditing of all locations in the value chain.

The performance of the suppliers is monitored continuously via the Supplier Code of Conduct audits, designed, maintained, and updated by the internal or external lead auditor. Fiskars Group applies business consequences to the supplier based on the latest Supplier Code of Conduct audit results. Any zero-tolerance findings lead to a failed audit result, regardless of the overall score, and the deviation process and business consequences for any current supplier with a failed audit result will be initiated.

During the reporting year 2024, 81 audits in total were performed by Fiskars Group auditor and 3rd party auditor. No supplier relationships were exited due to Zero Tolerance findings, while 2 supplier engagement workshops were held with suppliers in Asia. Further, during 2024 Fiskars Group became a member of SEDEX and AMFORI platforms and utilized the platform resource in supplier management.

Fiskars Group Due Diligence to Prevent Forced Labor and Child Labor – monitoring performance

Fiskars Group ensures risk mitigation and drives improvement in supplier compliance by setting annual supplier sustainability targets. KPIs are set to measure Supplier Code of Conduct performance relating to percentage of annual spend placed with low-risk suppliers for finished goods.

During the reporting year, two targets were set to monitor performance and drive actions. The first KPI relates to finished-goods spend with low-risk suppliers. The annual global spend with suppliers either from low-risk countries or receiving a low-risk result in the latest audit is set at 80%. The second KPI relates to ‘fail’ audit results resulting from a zero-tolerance finding due to a score below 60% and/or any zero-tolerance finding. The target level for this KPI is always zero. Both KPIs are updated monthly, and the updated result is shared in business reviews with the Supply Chain leadership teams.

In cases of SCoC audit findings and nonconformances, Fiskars Group closely follows up to ensure that the supplier has met the minimum compliance level and to encourage them to work towards better levels. Follow-up audits are conducted, and worker interviews are included in the audits when required, to verify suppliers’ corrections and improvements.

A Supplier Code of Conduct email account is open for contacting the Fiskars Group audit team to report misconduct, as instructed in the Supplier Code of Conduct. Investigation of and remediation of human rights breaches identified via the Ethics & Compliance Hotline is enabled and managed by the Legal team.

A Supplier Code of Conduct email account is open for contacting the Fiskars Group audit team to report misconduct, as instructed in the Supplier Code of Conduct. Investigation of and remediation of human rights breaches identified via the Ethics & Compliance Hotline is enabled and managed by the Legal team.

Fiskars Group Due Diligence to Prevent Forced Labor and Child Labor – reporting misconduct

Employees, external supply chain workers and other business partners can report suspected violations through an anonymous Ethics & Compliance helpline. The Company has country-specific anonymous hotline numbers available in the regions where it operates or have significant suppliers. Compliance helplines are provided by an external partner, NAVEX WhistleB, to ensure anonymity. Reports are responded to within seven days of filing, and all reported cases are handled confidentially and investigated by the Legal and Compliance function. Depending on the case, other relevant functions such as HR are engaged in the investigation.

Employees, external supply chain workers and other business partners can report suspected violations through an anonymous Ethics & Compliance helpline. The Company has country-specific anonymous hotline numbers available in the regions where it operates or have significant suppliers. Compliance helplines are provided by an external partner, NAVEX WhistleB, to ensure anonymity. Reports are responded to within seven days of filing, and all reported cases are handled confidentially and investigated by the Legal and Compliance function. Depending on the case, other relevant functions such as HR are engaged in the investigation.

The Fiskars Group Code of Conduct Violation Response Policy complies with the EU Whistleblowing Directive (EU) 2019/1937. It provides clear procedures for investigating suspected violations and applies to all employees and entities within the Fiskars Group. The policy defines how to report suspected code violations, what is considered a code violation, the confidentiality of reporting, prohibition of retaliation acts and freedom of liability, the rights of the subject of investigation, consequences of malicious reports, assessment of the report, investigation principles and post-investigation actions, including result reporting.

All reported cases are reported quarterly to the Board's Audit Committee, and to local law enforcement if necessary.

During 2024, Fiskars Group had a total of 46 reported misconduct cases. 21 reports were made anonymously through the ethics and compliance helpline and hotlines, 8 cases were received via management, 11 cases were received via HR, and 6 were reported via the compliance email address. Fiskars Group had no significant cases of noncompliance related to human rights.

About the Fiskars Group Supply Chain Due Diligence, Modern Slavery and Human Trafficking Statement 2024 and approval

This statement is prepared on behalf of Fiskars Group and its affiliates, in compliance with the UK Modern Slavery Act (2015), the California Transparency in Supply Chains Act (2010), the Norwegian Transparency Act (2022), and the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act (2023). Fiskars Oyj Abp is the ultimate parent company with head office in Helsinki, Finland.

This statement has been prepared for the financial year ending December 31, 2024.


California and Other States Notice of Information Collected and/or Disclosed

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) and privacy laws in Virginia, affords consumers residing in those states certain rights with respect to their Personal Information. If you are a California resident, including a business contact of one of our vendors or other type of business which transacts with Fiskars (collectively, “CA Business Contact”), or a Virginia resident, this section applies to you. 

Collection And Use of Personal Information

Fiskars offers a wide variety of products through our iconic brands (each a “Brand”). We may collect Personal Information from you in a variety of different situations, including, but not limited to our websites, your mobile device, through email, in physical locations, through the mail, over the telephone, and/or in any other situation where we interact with you, including through our Brands. More specifically, Fiskars collects the following categories of Personal Information from its Consumers, which will depend on the particular Business Purpose for which we collect it: 

Categories of Personal Information  Examples of Personal Information Collected 
 Identifiers.  

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers

CA Business Contact: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, phone number, email address, account name.

Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) or in the applicable state laws.  

A name, signature, physical characteristics or description, address, telephone number, employment, employment history, bank, date of birth, financial account information, credit card number, debit card number, medical information.

CA Business Contact: Name, signature, business address, telephone number.

Protected classification characteristics under California, Virginia, or federal law.

 

Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex, sexual orientation, veteran or military status, genetic information (including familial genetic information).

CA Business Contact: None. 

 

 Commercial information.  

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

CA Business Contact: None.

 Internet or other similar network activity.  

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

CA Business Contact: None.

 Geolocation data.  

Physical location or movements.

CA Business Contact: None.

 Inferences drawn from other personal information.  

Profile reflecting a person's preferences, characteristics, or behavior.

CA Business Contact: None.

 Sensitive Personal Information   

Financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation.

CA Business Contact: None.

Personal Information does not include deidentified information or aggregate consumer information.

Fiskars obtains the categories of Personal Information listed above from the following categories of sources:

    1. Directly from you. For example, from forms you complete or products and services you purchase, or when you communicate with us about our ongoing business relationship.
    2. Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.

How We Use Personal Information

We may use or disclose the Personal Information we collect from you or about you for the following business purposes:

    1. To fulfill or meet the purpose for which you provided the information. For example, if you disclose your name and contact information to ask us a question or inquire about our products or services, we will use that Personal Information to respond to your inquiry. When you sign up to receive information about products, services, or other benefits from us, we may use your information to facilitate communication about that product or service. If we seek to or do engage you as a vendor or other type of business relationship, we use your Personal Information to communicate about our potential, current, or former business relationship. 
    2. To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you.
    3. To provide you information about our products and services.
    4. To provide, support, personalize, and develop our websites, products, and services.
    5. To create, maintain, customize, and secure your account with us.
    6. To process your requests, purchases, transactions and payments, and prevent transactional fraud.
    7. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
    8. To personalize your website experiences and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law).
    9. To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
    10. For research, analysis, and business development, including to develop and improve our websites, products, and services.
    11.  To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    12. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA or other applicable laws or subsequently agreed to by you.
    13. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Fiskars' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Fiskars about our Consumers is among the assets transferred.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Fiskars has disclosed the following categories of Personal Information for a business purpose to the following categories of recipients:

Category of Personal Information    Categories of Recipients
 Identifiers.  Service providers, web hosting and internet service providers, information technology, customer service, cloud service, data analytics, marketing and advertising, our affiliates, third parties to whom you have authorize us to disclose your Personal Information in connection with a product, service or offering
 Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) or applicable state laws.  Service providers, information technology, customer service, data analytics, marketing and advertising, our affiliates, third parties to whom you have authorize us to disclose your Personal Information in connection with a product, service or offering
 Internet or other similar network activity.  Service providers, web hosting and internet service providers, information technology, cloud service, data analytics, marketing and advertising, our affiliates, third parties to whom you have authorize us to disclose your Personal Information in connection with a product, service or offering.
 Sensitive Personal Information.   Service providers, web hosting and internet service providers, information technology, customer service, cloud service, data analytics, marketing and advertising, our affiliates, third parties to whom you have authorize us to disclose your Personal Information in connection with a product, service or offering.

 

Sales of Personal Information

California law provides for certain disclosures about Personal Information we “sell,” which means certain scenarios in which Fiskars has disclosed Personal Information with third parties or affiliates, in exchange for valuable consideration. In the preceding twelve (12) months, Fiskars has not sold Personal Information.

Notice of Financial Incentive

California’s privacy law requires that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of Personal Information, which it defines as a “financial incentive.” We offer discounts, coupons, or other and other product incentives to prospective and current Fiskars Brand consumers, including our Royal Copenhagen Collector’s Club. Sometimes, consumers sign up or provide us their Personal Information (e.g., email address, names phone numbers) in order to receive our discounts, coupons, warranties, or other product incentives. As such, under the CCPA, our discounts, coupons and product incentives may be considered financial incentives provided in exchange for the collection and retention of Personal Information.

We offer these discounts, coupons and other product incentives to enhance our relationship with you or so you can enjoy or try our products at a lower price. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in each such program offering.

  

The consumer data received in exchange for your participation is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings and whether and to what extent you opt out of any offerings but is roughly equivalent to the value of the coupon or product offered.

Retention of Personal Information

 We will not retain your Personal Information for longer than is reasonably necessary to carry out the purposes we disclose in this policy. 

 

Information Relevant to California and Other States

Targeted Advertising and California Sharing of Personal Information 

The CPRA requires that we notify you if we “Share” your Personal Information with third parties. For purposes of the CPRA, “Sharing” means that we make available or otherwise disclose your information to third parties for cross-context behavioral advertising, such as targeting of advertising to you based on your Personal Information obtained from your activity across businesses, websites, apps, and services other than our Services. 

Similarly, the VCDPA requires that we notify you if we use your information for Targeted Advertising. Targeted Advertising means displaying advertisements to you where the advertisement is selected based on Personal Information obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests

Accordingly, we “Share” and use your information for Targeted Advertising. Specifically, we disclose your identifiers and internet or other network activity with Service Providers and third parties with whom you direct us to disclose your Personal Information.  In order to opt-out of sharing and/or Targeted Advertising relating to your Personal Information, please click here to exercise that right. 

Sensitive Personal Information

Privacy laws in California and Virginia specify certain rights with respect to our collection of certain information those laws designate as “Sensitive Personal Information.”  We obtain consent to collect that information in those states where consent is required.   Moreover, each state’s privacy laws may consider different pieces of information to be “Sensitive Personal Information.” When we notify residents of certain states that we collect Sensitive Personal Information, that means that we collect Sensitive Personal Information within the meaning of the law of that particular stateWe collect Sensitive Personal Information in California and VirginiaWe collect the following types of Sensitive Personal Information, to the extent included in your state’s definition: Financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation.

Global Privacy Control 

You can also opt out of certain sharing and sales by visiting our Services with a recognized universal choice signal enabled (such as the Global Privacy Control). Please note that, depending on which opt-out preference signal you use [and whether you are logged into your account with us], our processing of the signal may be limited to the specific browser or device that you are using]. You may need to renew your opt-out if you use a different browser or device to access our Services.

Your Consumer Rights and Choices

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, and sell, and to access your information, (2) request deletion of your Personal Information, (3) request correction of your Personal Information and (4) not be discriminated against for exercising these rights, (5) limit processing of Sensitive Personal Information.

Access to Specific Information and Data Portability Rights

You have the right to request that Fiskars disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (See Exercising Your Rights below), we will disclose to you:

    1. The categories of Personal Information we collected about you. 
    2.  The categories of sources for the Personal Information we collected about you. 
    3. Our business or commercial purpose for collecting that Personal Information.
    4. The categories of third parties with whom we disclose that Personal Information.
    5.  The specific pieces of Personal Information we collected about you.
    6. If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Fiskars delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:

    1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    2.  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    4. Comply with a legal obligation.

Right to Limit Processing of Sensitive Personal Information

In California, you have the right to limit our processing of Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services.  When we collect your Sensitive Personal Information, we collect and use that information in order to perform the services or provide the goods for which that information is necessary and as reasonably expected by you.  Moreover, we do not use your Sensitive Personal Information for the purpose of inferring any characteristics about you.  We will notify you if we use your Sensitive Personal Information for purposes you might not reasonably expect so that you can request that we limit that processing.  Where your state’s privacy law requires that we obtain consent or provide an opt-out in order to collect or process Sensitive Personal Information, we do so.

Right to Correction

You have the right to correct inaccurate Personal Information maintained by us. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will correct (and direct our service providers to correct) your inaccurate Personal Information from our records, unless an exception applies.

Exercising Your Privacy Rights

To exercise the access, data portability, correction, and deletion rights described above, as well as to request that we limit our processing of your sensitive personal information, please submit a verifiable consumer request to us by either:

    1. Calling us at 1-888-720-3485 
    2. Contacting our Customer Service

Only you or a person authorized to act on your behalf may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
    2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

If we deny your request, you may appeal our decision by contacting us at [email protected]. Please clearly denote that it is an appeal. 
  

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


Changes to Our State-Specific Privacy Notice

We may change this privacy notice from time to time. If we make changes to this privacy notice, we will notify you by revising the Effective Date at the top of this policy and in, in some cases, we may provide you with additional notice, such as adding a statement of notice on the websites or sending you a notification. We encourage you to review this policy regularly to stay informed about our information practices and the choices available to you.

Contact Information

If you have any questions or comments about this notice, the ways in which Fiskars collects and uses your information described above (and in the Fiskars Group Consumer Privacy Policy, found here), your choices and rights regarding such use, or how to exercise your rights under state law, please do not hesitate to contact us at:

Phone: 1-877-720-3485

Email:  [email protected]

Postal Address:
ATTN: Legal and Compliance Department

Fiskars Brands, Inc.

7800 Discovery Drive, Middleton, WI 53562

Calling us at: 1-877-720-3485. 
Contacting our Customer Service:  https://www.royalcopenhagen.com/en-us/contact-customer-service 
By Mail at:  Fiskars Living US, LLC., 1330 Campus Parkway, Wall, NJ, 07753