Consumer and Customer Privacy Notice
Applicable since 26-4-2018; last updated on 26-1-2019
Global Health Supplements B.V. respects your right with regards to data privacy and data protection when you communicate (online or offline) with us through our various websites, mobile applications, offline programs and events. We have therefore developed this Privacy Notice to inform you how each Global Health Supplements B.V. related entity in the UK & Ireland (unless stated otherwise - “Global Health Supplements B.V.”, “we,” or “our”) collects, stores, uses, shares, processes and protects the personal information about our consumers (“you”). It also tells you how you can access and update your personal information and make certain choices about how your personal information is used.
By using our websites, applications or by otherwise giving us your personal information you are accepting the practices described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use our websites or applications or give us any of your personal information. We reserve the right to make changes to this Privacy Notice at any time. Any changes will be posted in this Privacy Notice and material changes will be prominently notified on the respective website or application this Privacy Notice applies to or will be otherwise communicated to you prior to the change becoming effective. We encourage you to regularly review this Privacy Notice to make sure you are aware of any changes and how your information may be used.
Please be informed that the Global Health Supplements B.V. related entity in the UK or Ireland which operates the website you are visiting or service you are receiving (as the case may be) is the Data Controller of any personal information you submit to Global Health Supplements B.V.. If you have any queries over who is your Data Controller please Contact Us.
If you have any requests concerning your personal information or any queries with regard to this Privacy Notice please Contact Us.
1. What does this Privacy Notice apply to?
This Privacy Notice applies to personal information that we collect from or about our consumers or customers through the methods described in this section. Please note we may combine personal information that we collect via one method (e.g., a website) with personal information that we collect via another method (e.g., an offline event).
We do this to get a more complete view of our consumers, which, in turn, allows us to serve you better and with more customisation.
1.1 Global Health Supplements B.V. websites
This refers to any consumer-directed websites operated by Global Health Supplements B.V., including websites that we operate under our own domains/URLs and websites that we run on third party social networks such as Facebook (e.g. Facebook fan page).
1.2 Global Health Supplements B.V. mobile sites/applications
This refers to any consumer-directed mobile sites or applications operated by Global Health Supplements B.V., including our smartphone apps (e.g., iPhone apps).
1.3 Global Health Supplements B.V. text messaging programs
This refers to any consumer-directed text messaging programs operated by Global Health Supplements B.V.. These programs might be advertised on one of our websites or applications or in a print ad.
1.4 Offline registration cards
This refers to printed registration and similar cards that we may collect from consumers via postal mail, in-store demos, or other offline events.
1.5 Call centres
This refers to personal information that we may collect from consumers through our call centres, for example if you call us with a question or comment or to sign up for marketing communications over the phone.
1.6 Data from other sources
This refers to personal information we may obtain about you from other sources. For example, we may hire a third party data aggregator to provide us additional information about our existing consumers (this is known as “data appending”) or we may use a third party to collect consumer data from our online advertisements. We may also receive information from third party co-sponsors who we may occasionally partner with to run special contests or other promotions. We may also receive information about consumers when we acquire other companies or businesses.
2. What information do we collect?
Depending on how you interact with us (online, offline, over the phone, etc.), we may collect from you various types of information (personal and aggregate), as described in this section.
Personal information (as used in this Privacy Notice) refers to such types of information that can be used to personally identify you, whereas aggregate information does not allow for such identification on its own.
In some instances (and unless we say otherwise below), we may combine/link one type of information with another type of information (e.g., personal contact information with account login and/or demographic information) and store them together in our records. In cases, where personal and aggregate information are combined, such information will always be considered as personal information. We strive to limit the amount of personal information we collect and store to that which is reasonably necessary to provide you the relevant services. We generally store your personal information for as long as your account is active with us or as needed to provide you the relevant services. We may store your personal information for a longer period of time to comply with legal or regulatory obligations, resolve disputes, enforce our agreements, or for records management purposes.
2.1 Personal contact information
This includes any information that would allow us to personally contact you, such as your name, home or mailing address, phone number (home, mobile phone, etc.), or email address. In some cases, this could include personal information that you give us about someone else (for example, if you provide a friend’s email address for a tell-a-friend program). We typically collect personal contact information in connection with a variety of activities, including general website registration, newsletter sign-up, website community features, online purchases, customer service inquiries, contests and other promotions, and consumer surveys. If you create an account with us, your personal contact information may be stored under your account profile.
2.2 Account login information
This refers to any information that is required for you to establish a unique account with us or for us to give you access to your specific account profile. Examples may include your login ID/email address, screen name, password, and/or security question and answer. We only collect unique login information for those activities that require an account, such as general website registration, newsletter sign-up, and website community features. Your login information, especially your password, should be kept confidential and never shared with anyone else. To change your login email address or password, log in to the relevant edit account section of our site (if available) or Contact Us.
2.3 Demographic information
This includes any information that describes your demographic or psychographic characteristics. Examples may include your date of birth, age or age range, gender, geographic location (e.g., post code, city and state, mobile location), favourite products, hobbies and interests, and household or lifestyle information. We typically collect demographic information in connection with a variety of activities, including general website registration, newsletter sign-up, website community registration, contests and other promotions, and consumer surveys. If you create an account with us, you may be allowed to modify certain demographic information stored under your account. To do so, log in to the relevant edit account section of our site (if available) or contact Consumer Services. For demographic information stored under your profile on a third party social network (e.g., Facebook), see separate paragraph on “Social network info.”
2.4 Technical computer information
This includes any information about the computer system or other technological device that you may be using to access one of our websites, applications or online advertisements. We typically collect this information through automated technologies such as cookies and web beacons. Examples of technical computer information may include your computer’s IP address, operating system type, and web browser type. If you access a Global Health Supplements B.V. website or application via a mobile device such as a smartphone, the collected information may also include your phone’s unique device ID, and other similar mobile device data.
2.5 Website usage information
This includes information about how you use and navigate our websites, applications and online advertisements, including which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with a Global Health Supplements B.V. website or application (e.g., date and time of visit, which site you came from, favourite recipes and site activities, high game scores, etc.). This information is captured using automated tracking technologies such as browser cookies, flash cookies, and web beacons, and may also be collected through the use of third party tracking services (such as Google Analytics) that collect data in aggregate (such as number of visits to a particular page, or the amount of time spent on a web site). We may also use these technologies, such as web beacons, to capture information about how users respond to certain email campaigns (e.g., time the email is opened, where user links to from the email, etc.).
2.6 Consumer feedback
This includes information that you voluntarily share with us about your experience in using our products and services, including our websites and applications. Examples may include unsolicited comments and suggestions, testimonials, or other questions or feedback related to our products. We typically collect this information in the form of consumer surveys, consumer panels, contact forms, “Ask the Expert” forms, and email correspondence.
2.7 Consumer-generated content
This refers to any content that you create and then share with us (and perhaps others) by uploading it to one of our websites or applications, including one of our Facebook sites. Examples may include photos, videos, personal stories, or other similar media or content. We may collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third party social networking.
2.8 Social network information
This refers to any information that is part of your profile on a third party social network (such as but not limited to Facebook) and that you allow the third party social network to share with us. Examples include your basic account information (e.g., name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share with third party application developers. For example, we may receive your social network profile information (or parts of it) every time you download or interact with a Global Health Supplements B.V. web application on a social network such as Facebook or Twitter or every time you use a social networking feature that is integrated within a Global Health Supplements B.V. website (such as Facebook Connect). To learn more about how your information from a third party social network may be obtained by us (or other third party application developers), please visit the website of the relevant social network. You further acknowledge using your personal information to match information with a social network for advertising purposes.
2.9 Payment information
This includes any information that you use to make a purchase, such as your credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). This also includes the billing name and address associated with your form of payment. If you create an account with us when making a purchase, your payment information may be stored under your account profile. To review or edit this information, log in to the relevant edit account section of our site (if one is available) or Contact Us.
2.10 Other information (depending on context)
This refers to any other information that we might need to collect for a specific Global Health Supplements B.V. form, feature, or other service that you use or request. What this information includes will vary depending on the method of collection and the specific purpose(s) for which the information is being collected.
3. For what purposes do we use your personal information?
3.1 Account maintenance
We may use your personal information to maintain your accounts with us, including administering any consumer loyalty or rewards programs that are associated with your account. This typically involves the use of personal information that was originally collected to set up your account (e.g., personal contact information, payment information, account login information, demographic information, etc.).
3.2 Customer service
We may collect and use your personal information to provide you customer service, including responses to your inquiries. This typically requires the collection and use of certain personal contact information (such as your name or email address) and information regarding the reason for your inquiry (e.g., order status, technical issue, product question/complaint, general question, etc.). Customer service may be provided through various forms of communication, including email correspondence, call centre support, and live online chat features.
3.3 Product improvement and customisation
We may collect and use your information so we can constantly improve our products, tailor them to your needs, and come up with new product ideas. This mostly involves the collection and use of demographic information and consumer feedback.
3.4 Consumer engagement
We may collect and use your personal information to encourage you to be more actively engaged with our products and services (including our websites and applications), thereby increasing overall brand engagement and awareness. This mostly involves the collection, use, and publication of consumer-generated content.
3.5 Contests and other promotions
We may collect and use your personal information to administer a contest, sweepstakes, giveaway, competition, or other similar marketing campaign or promotion. These events typically require the collection and use of personal contact information (for prize fulfilment), demographic information (for eligibility determination), and, in some instances, consumer-generated content. Some of our promotions may be run on third party social networks such as Facebook (for example, on our Facebook fan pages). To comply with legal requirements, we may publish or share a limited amount of personal information (such as name and city of residence) about the winners of a particular promotion. For more information about our contests and other promotions, please see the official rules or details posted with each promotion.
3.6 Marketing communications
We may collect and use your personal information to send you marketing communications, such as email communications, SMS text messages, and postal mailings. Please note that if you choose to receive SMS text messages, your mobile service provider’s fees for messaging will apply. We may also show you marketing communications on other websites, including on social media sites where you are a member, by matching activities or information collected on our websites and online advertisements with those collected on third party sites (“Targeted Advertising”). These marketing communications will keep you up-to-date on the latest news, events, special offers, and promotions from our brands of interest to you. On occasion, these communications may also introduce you to other Global Health Supplements B.V. brands and inform you about offers and promotions from other third party companies. Sending you marketing communications mostly requires the collection and use of certain personal contact information and demographic information. In some instances (such as for mobile apps and text messaging programs), this could involve the use of your precise geo-location, which may allow us to send you location-based offers and promotions.
You can always opt-out from receiving marketing-related email communications or text messages by following the unsubscribe instructions provided in each such communication. If you have an account with us, you may be given the option to change your communication preferences under the relevant edit-account section of our site (if available) or by contacting us. Changing these preferences would also remove you from our lists for future Targeted Advertising. You may also visit social media sites where you are a member to explore opt out options they may provide for Targeted Advertising. Please note that even if you opt out from receiving marketing communications from us, you may still receive administrative communications from us, such as order confirmations, notifications about your account activities (e.g., account confirmations, password changes, etc.), and other important announcements. You will also still see generic ads on other websites, including on social media sites where you are a member.
3.7 Third party social networking
We may collect and use your personal information when you interact with third party social networking features such as “Facebook Connect” or “Facebook Like”. These features may be integrated in our sites or applications for the purposes of running contests (or similar activities), allowing you to share content with friends, or other stated purposes. If you use these features, we may have the ability to obtain certain information about you from your social networking profile (see “Social network information” under Question 2 of this Privacy Notice). You can learn more about how these features work, and the profile data we may obtain about you, by visiting the website of the relevant third party social network.
3.8 Website improvement and personalisation
We may collect and use your information to improve and personalise your experience on our websites, applications and online advertisements. This is typically done through automated tracking technologies (please also see Question 8) that collect and remember certain account login information, technical information, and/or previous website usage information. For example, we might remember your login ID/email address or screen name so you can quickly login the next time you visit our site or so you can easily retrieve the items you previously placed in your shopping cart. Based on this type of information, we may also show you specific Global Health Supplements B.V. content or promotions that are tailored to your interests.
3.9 Website community features
We may collect and use your personal information to give you access to website community features, including features that may allow you to upload and share recipes, pictures, videos, artwork, or other messages or content. This typically involves the collection, use, and (in some instances) public display of certain personal contact information, account login information, demographic information, and/or consumer-generated content. Because these features are “communal” in nature, information or content that you post in these areas may be visible to others. Please use caution when using these features or uploading content to a Global Health Supplements B.V. site. For some community features, we may give you the ability to control whether some parts of your profile can be seen by others. To access these settings, log in to the relevant edit account section of our site (if one is available) and access your community profile. For website community features that have social networking integration (such as “Facebook Connect”), see separate paragraph on “Third party social networking”.
3.10 Website viral features (e.g., tell-a-friend)
We may request and use your personal information so you can use website viral features, such as our tell-a-friend features. These features allow you to easily share certain news, product information, promotions, wish list items, or other content with family members and friends. These features typically require the collection and use of personal contact information (such as names and email addresses) so that the selected one-time message or content can be delivered to the proper recipients. In most cases, we do not retain the information provided. In some cases (for example, as part of a refer-a-friend program), we may store the information so we can track and reward consumers for their successful referrals. For tell-a-friend or other viral features administered by third party social networks (such as Facebook’s “Share” and “Like” features), please refer to the website of the relevant social network for additional information.
3.11 Order fulfilment
We may collect and use your personal information to process and ship your orders, and to inform you about the status of your orders. This could involve the collection and use of certain personal contact information, payment information, account login information, and/or other information related to your purchase (such as products ordered). This could also involve the on-going storage of your payment information to allow for easier checkout on future purchases. Where orders are being fulfilled by a third party, we will share your personal information with them for the purposes of fulfilment of the order. You may, as a result, also receive communications from that third party (whether by email, SMS or other methods of communication) regarding the fulfilment of the order.
3.12 Other general purposes (e.g., website security, internal research)
We may collect and use your information for other general business purposes, such as to maintain the day-to-day operation and security of our websites and applications and to conduct internal marketing and demographic studies. These activities mostly require the collection and use of certain demographic information, technical computer information, website usage information, and consumer feedback.
4. How do we protect your personal information?
We take all necessary technical and organisational measures to protect the confidentiality and security of your personal information collected through the various methods described in this Privacy Notice. These efforts include, but are not necessarily limited to: (i) storing your personal information in secure operating environments that are not available to the public and that are only accessible to authorized Global Health Supplements B.V. employees, and our service providers, agents and those with whom we have contracts; (ii) using industry-standard SSL encryption (or similar) to protect the security of certain sensitive personal information (such as credit card information, health or patient information) during transmission, and, (iii) verifying the identities of registered users before they can access the personal information we maintain about them.
5. What happens if you refuse to provide your personal information?
If you choose not to submit any personal information when requested, you may not be able to participate in certain activities and personalised features and may limit the services and special offers we can provide you. For example, if you do not wish to share with us your email address, you will not be able to receive any of our electronic newsletters or otherwise register on our websites or use our applications. If you refuse to provide your credit card number, you will not be able to purchase products at a Global Health Supplements B.V. Online Store. However, to simply browse our websites and learn more about our products, you do not need to give us any personal information.
6. Who do we disclose your personal information to and why?
Global Health Supplements B.V. will never share your personal information with any third party that intends to use it for direct marketing purposes unless we have specifically informed you and you have given us specific permission to do this.
We may share your personal information with our subsidiary companies, companies in which Global Health Supplements B.V. S.A. has control through either direct or indirect ownership (collectively “Global Health Supplements B.V. Group”). Some of these are located outside the EEA. Global Health Supplements B.V. may also share your personal information with third parties (some of whom are outside the EEA), but only in the following circumstances:
6.1 Service Providers, Agents and Contractors