1. We respect your privacy
We are committed to safeguarding personal privacy. Unless we have your consent to do otherwise, or this is permissible by, or required by, law, we will only collect and use personal information as set out below.
2. Your Personal Information
Personal information that you may be requested to provide when using our Website, or our Services, includes but is not limited to:
your full name, date or birth, address, email address and phone number;
sensitive Information about you (set out at clause 3 below);
information about your experience with our Services;
your individual preferences;
your online behaviour and interests based on your online browsing activity (including social interactions);
information automatically collected by our software which includes IP Address, cookies data, performance specifications of your hardware and software, date and time of access to our Website and the URL of the page requested;
the contact details of third parties - if you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to us and used for the purposes set out in this policy (which may include using their details for marketing and social media purposes);
any other personal information which you directly provide to us; and
any other personal information requested or required for the purpose of providing the Services.
3. Sensitive Information
We may collect some or all of the following types of sensitive information (Sensitive Information):
- Health information – such as but not limited to, information about past or current illnesses, diseases, viruses, conditions, disorders, medical history, treatment records, past and current pharmaceutical drug use, blood type, images, photographs, x-rays and family medical histories;
- Ethnic or racial origin information;
- Religious belief information;
- Genetic information; and
- Biometric information.
4. Collection of Personal Information
1. Active Information Collection
Personal information may be collected by us if you:
- request the provision of Services through our Website;
- subscribe to any alerts, information releases, news, newsletters, updates and media releases about our products or services;
- complete and submit any forms to us through our Website;
- communicate with any other users on our Website;
- contact us directly in person or via any medium including but not limited to by email, mail, telephone, social media and via the contact form on our Website;
- participate in any offers, promotions or marketing activities;
- interact with our Website for a specific purpose; or
- interact with or browse our Website generally.
Personal information is requested in order to facilitate or provide you with Services, certain content, and information about such content, products or services, any marketing materials, newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Services, offers, or events which may be of interest.
You are not obliged to provide personal information. However, failure to do so may result in us, and other users of our Website, being unable to provide you with Services or certain content.
2. Passive Information Collection
- We may also collect information which tells us about visitors to our Website. For example, we may collect information about the location, date, time and duration of visits and which pages of our Website are most commonly accessed. This information is generally not linked to the identity of visitors. By accessing our Website via links in an email we have sent and/or by accessing our Website generally, you consent to the collection of such information where it is personal information.
- Certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Data Protection Act 2018.
- Your Internet browser automatically transmits to our Website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using.
- We use passively collected anonymous information or personal information to provide better service to our Website’s visitors and customers, customise our Website based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve our Website for your use.
- By accessing our Website, you consent to information about you being collected, compiled and used in this way.
The collection of personal information is neither intended for, nor directed to, persons who are under the age of eighteen (18) years old. Persons under age eighteen (18) may only use our Website with the involvement and consent of a parent or legal guardian.
6. Purpose for collection, use and disclosure of personal information
Personal information and Sensitive Information will be collected, held, used and disclosed for any of the following primary purposes set out below, noting that in disclosing your personal information we will look to minimise the disclosure of your Sensitive Information:
- To render Services to you through our Website;
- Where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety, or a serious threat to public health or safety;
- To maintain the functionality of our Website, including the provision of information to you relating to the content available on our Website and e-commerce transactions conducted via our Website;
- To send you any technical, administrative or legal notices, whether or not these are important to our Website;
- To fulfil obligations in respect of any transaction made on our Website;
- To provide you with information about your transactions, content and services, to provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone or any other form of electronic, emerging, digital or conventional communications channel;
- To maintain our relationship with you;
- To provide you with newsletters via mail and electronic newsletters (e-newsletters);
- To respond to enquiries, complaints and complaints handling;
- To improve the Services, our Website and system administration;
- To record statistical data for marketing analysis and to conduct market research;
- To perform data analytics on the data and Sensitive Information that we collect (noting that the data and Sensitive Information will be de-identified so that personal information will remain confidential) for health and lifestyle trends (Health Data);
- To provide, by way of sale or otherwise, Health Data to third parties;
- To share personal information with our promotional partners and other trusted third parties in the manner described below;
- To the extent permissible by law, for any other purpose as may be deemed reasonably necessary by us in the circumstances.
7. Protection of Personal Information
We reserve the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect our rights or property, or any member of the public, to protect the integrity of our Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.
8. Storage and Security of Personal Information
We will endeavour to take all reasonable steps to keep secure any personal information recorded (including your Sensitive Information details). The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas or may be operated by cloud computing whose servers are based in another country.
9. Transborder Data Flows
However, in general, we do not send personal information to foreign countries. On occasion, we may be required to transfer personal information to someone who is in a foreign country if:
- we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which upholds principles for handling the information that are substantially similar to the Data Protection Principles;
- The individual gives informed consent;
- It is not practicable for the individual to give consent, but the transfer of information is for his or her benefit;
- Transfer is necessary for performance of a contract between the individual and us and is in the interests of the individual;
- Action is required in relation to an unlawful activity; or
- Disclosure is required by law.
The country to which the information is sent would depend on the individual circumstances of the case.
If it becomes necessary to store or disclose personal or sensitive information outside of the United Kingdom, where practicable an indemnity will be sought from the recipient of the information, which indemnifies us and you against claims for the recipient’s breach of the Data protection Act 2018.
10. Destruction of Personal Information that is not required
- We destroy all personal information (including Sensitive Information) which we no longer require.
- Secure disposal of electronic records will include overwriting records before they are deleted and deleting backup files.
- Secure disposal of paper based records will include shredding of paper files or using an authorise disposal company for secure disposal.
- In situations where it is necessary to retain the personal information, it will be permanently de-identified by removing form the record any information by which a person may be identified.
11. Links to Other Websites
Our Website may contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy policies, practices or statements. We are not responsible, nor do we accept any liability, for the conduct of organisations linked to our Website.
12. Access and Correction to Your Personal Information
You have the right to access, review and amend your personal information that may be recorded on our database. Information may be reviewed by contacting our privacy officer via email: email@example.com. Please allow up to 30 days for this request to be processed.
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Data Protection Act 2018.
13. Data Retention
We retain your personal information for as long as is necessary or your account is active or as needed to provide you with Services on our Website, or to allow other third parties to provide you with services. If you no longer want us to use your personal information to provide you with services, you may close your account. However, we may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreement.
14. Sale of Company
15. Changing and Deleting Information we have about you
- Information contained on the database may be deleted if you send a request to our privacy officer via email: firstname.lastname@example.org. Please allow up to 30 days for this request to be processed.