VITAFLO (INTERNATIONAL) LIMITED ("VITAFLO"), COMPANY NUMBER 3380926 – DATA PROTECTION REGULATIONS
Valid from May 2018
SCOPE OF APPLICATION OF THESE DATA PROTECTION REGULATIONS
Thank you for visiting this website. We hope you enjoy finding out more about Vitaflo and our products.
Vitaflo respects your right to privacy and the protection of personal data online when you use our website and communicate with us electronically. We take all necessary measures to protect the personal data you provide.
You are hereby informed that Vitaflo (International) Ltd is the entity responsible for your personal data.
Please read this Privacy Notice ("Notice") carefully to understand our policies and practices in relation to your personal data and how it is handled. This Notice applies to individuals who interact with Vitaflo services ("You"). This Notice explains how your personal data is collected, used and disclosed by Vitaflo ("Vitaflo", "We", "Us"). It also explains how you can access and update your personal data and make specific choices about how your personal data is used.
These Data Protection Conditions apply to both our online and offline data collection, including personal data that we collect through our various channels such as websites, apps, social networks and events by third-party providers. Please note that we may collate personal data from different sources (website, offline event). As part of this, we may combine personal data originally collected by different partners. See Section 9 for information on your rights.
If you do not provide us with the required personal data (we will inform you of this by making this information clear, for example, in our registration forms), we may not be able to provide you with certain services. These Data Protection Regulations may change from time to time (see Section 11).
This Data Protection Policy contains important information in the following areas:
- SOURCES OF PERSONAL DATA
- PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
- PERSONAL DATA RELATING TO CHILDREN
- COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
- USE OF YOUR PERSONAL DATA
- DISCLOSURE OF YOUR PERSONAL DATA
- STORAGE OF YOUR PERSONAL DATA
- DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
- YOUR RIGHTS
- YOUR CHOICES ABOUT HOW WE USE AND SHARE YOUR PERSONAL DATA
- CHANGES TO THE DATA PROTECTION POLICY
- ENTITY RESPONSIBLE FOR DATA PROCESSING & CONTACT
1. SOURCES OF PERSONAL DATA
These Data Protection Conditions apply to personal data that we collect from you or about you using the methods described below (see Section 2) from the following sources:
Vitaflo websites
Consumer-facing websites operated by or for Vitaflo, including websites that we operate under our own domain name/URL and mini-websites that we operate on social networks of third parties, such as Facebook.
Websites for mobiles/apps
Websites for mobiles or applications operated by or for Vitaflo, such as smartphone apps.
E-mail, text messages and other electronic messaging
Electronic interaction and communication between you and Vitaflo.
Offline registration forms
Printed or digital registration forms and similar forms that we collect, for example, by post, in contests/competitions and other promotions or events.
Data that we compile
In our interactions with you, we may compile personal data about you (e.g. records of forms that you submit via our website).
Data from other sources
Social networks of third parties (e.g. Facebook, Google), market research (if feedback is not anonymised), data aggregation by third-party providers, advertising partners, public sources and data that we obtain through the acquisition of other companies.
2. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Depending on how you interact with Vitaflo (online, offline, by telephone, etc.), we collect various types of information from you, as described below.
Personal contact information
This includes any information you make available to us so that we can contact you, e.g. your name, postal address, email address, social network data or telephone number.
Demographic information and interests
Any information that describes your demographic or behavioural characteristics. Examples include your date of birth, age or age group, gender, geographical location (e.g. postcode), favourite products, hobbies and interests as well as household or lifestyle information.
Information from the computer/mobile device
Any information about the computer system or other technical devices you use to access one of our websites or applications, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, the type of operating system and the type and version of Internet browser. If you access a website or app via a mobile device, such as a smartphone, the information collected will also include, where permitted, the unique device ID of your telephone, advertising ID, geographical location and other similar mobile phone data.
Information on the use of websites/communication
When you navigate through and interact with our websites or newsletters, we use automatic data collection technologies to collect certain information about your activities. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of time spent on certain pages. This information is collected for analysis and advertising purposes using automated technologies, such as cookies and web beacons, and is also collected through the use of tracking technologies by third parties. In particular, you have the right to withdraw your consent to the use of such technologies. Further details can be found in Section 4.
Market research & customer feedback
Any information that you voluntarily provide to us about your experience of using our products and services.
Content generated by the consumer
Any content that you generate and then make available to us on social networks of third parties or by uploading to our websites or applications, including the use of applications for social networks of third parties such as Facebook. Examples include photos, videos, personal stories or other similar media or content. Where permitted, we collect and publish consumer-generated content in connection with a variety of activities, including contests/competitions and other promotions, community functions of websites and social networks of third parties.
Information from social networks of third parties
Any information that you disclose publicly on a social network of a third party or in your profile on a social network of a third party (e.g. Facebook) and that you allow the third-party social network to share with us. Examples include your essential account information (e.g. name, email address, gender, date of birth, current place of residence, profile picture, user ID, friends list, etc.) and any other additional information or activity that you allow the third-party social network to disclose. We receive your profile information from the third-party social networks (or parts thereof) each time you download or interact with a Vitaflo Internet application on a social network, such as Facebook, each time you use a social networking function that is embedded in a Vitaflo website (such as Facebook Connect), or each time you interact with us through a third-party social network and process information only to the extent permitted. If you would like to learn more about how your information is obtained from a social network by Vitaflo or if you do not wish such information to be passed on, please visit the website of the relevant social network of the third-party provider or contact us. For more information on data processing in connection with third-party social networks, please see Section 5.
Special category data
We process certain special category data that you make available to us, with your prior explicit consent, for marketing purposes. We process your sensitive personal data for other purposes on the following legal basis: (i) detection and prevention of crime (including fraud prevention); and (ii) compliance with applicable law (e.g. to comply with our diversity reporting).
3. PERSONAL DATA RELATING TO CHILDREN
We do not knowingly ask for or collect personal data from children under 16 years of age. If we become aware that we have inadvertently collected personal data from a child under the age of 16, we will promptly remove that child's personal data from our records. However, Vitaflo may collect personal data from children under the age of 16 directly with parental or guardian agreement or with express parental or guardian consent.
4. COOKIES / SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
Cookies / similar technologies
Please read our Cookie Notice to learn how to manage your cookie settings and to obtain detailed information about the cookies we use and the purposes for which we use them.
Log Files
We collect information using log files that record your activities on the website and collect statistics about your browsing habits. These data entries are generated automatically and help us to correct errors, improve performance and ensure the security of our websites.
Web Beacons
Web beacons (also known as "web bugs") are small strings of code that provide a graphical image on a web page or in an email to transmit data back to us. The information collected via web beacons includes information such as the IP address, as well as information about how you react to an email campaign (e.g. when the email was opened, which links you click on in the email, etc.). We will use web beacons on our websites or insert them into emails that we send you if you have given us your consent to do so. We use information from web beacons for a variety of purposes, including, but not limited to, reporting on website browsing behaviour, ascertaining visitor numbers, advertising, email auditing and report-generation and personalisation.
5. USE OF YOUR PERSONAL DATA
The following sections describe the different purposes for which we collect and use your personal data and the various types of personal data collected for each purpose. Please note that not all of the uses listed below are relevant to each individual.
| What we use personal data for | Our legal basis | Our legitimate interests |
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Contests/competitions, marketing and other advertising. We use your personal data with your consent (where required) to make available to you information about goods or services (e.g. marketing communications, campaigns or promotions). This may be by email, announcements, text messages, telephone calls and mailing, where permitted by law. Some of our campaigns and promotions are conducted on websites of third parties and/or social networks. This use of your personal data is voluntary, which means in particular that, in relation to this, you can give us your consent or withdraw your consent or object to data processing. Detailed information on how you can change your marketing communication preferences can be found below in Sections 9 and 10. For more information about our contests/competitions and other promotions, please refer to the official rules or details published during each contest/competition or each promotion. |
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Social networks of third parties: We use your personal data when you interact with social networking functions of third-party providers, such as "Like" functions, to provide you with advertising and to contact you on social networks of third-party providers. We must point out that you use the respective offered third-party social networks and their functions at your own risk. This applies in particular to the use of interactive functions (e.g. sharing, rating). In principle, we have no influence on the type and scope of the data processed by the respective third-party provider of social networks, the type of processing and use or passing on of this data to third parties. You can find out more about how these functions work, about the profile data we receive about you and how to opt out, by reading the privacy notice of the relevant third-party social networks. We and the respective third-party provider of the social network are jointly responsible for individual processing operations (e.g. Facebook Insights): In particular, we and the third-party providers of the respective social network act as jointly responsible entities for web tracking methods used by the respective third-party providers of the social network. Web tracking can also take place irrespective of whether you are currently logged into or registered with the social network. In principle, we ourselves receive only anonymised statistics and in principle have no access to personal data. Facebook: For Facebook fan pages, we analyse how you use our fan page in joint responsibility with Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (Facebook). You can find information on this in Facebook's data protection information: https://www.facebook.com/legal/terms/information_about_page_insights_data. The relevant content of the joint responsibility agreement can be found at the following link https://www.facebook.com/legal/terms/page_controller_addendum. Facebook is the common point of contact and processes all requests relating to the rights of affected persons. You have the right to object to the processing of your data. In addition, we use the services of the platform of Pinterest Inc, 808 Brannan St, San Francisco, CA 94103-4904 (Pinterest). We are responsible jointly with Pinterest for data processing on our Pinterest channel. We also use the "Pinterest Analytics" function, which enables us to view statistical analyses relating to our channel. Further information on data protection can be found in Pinterest's data protection information: https://policy.pinterest.com/de/privacy-policy. We also use the services of the platform of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103 (Twitter). We can use the dashboard provided by Twitter to call up statistics, e.g. whether a tweet has been opened or liked or about our followers. Further information on data protection can be found in Twitter's data protection information: https://twitter.com/de/privacy |
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Personalisation (offline and online) With your consent (if required), we use your personal data (i) to analyse your preferences and habits, (ii) to anticipate your requirements based on our analysis of your profile, (iii) to improve and personalise the user-friendliness of our websites and apps, (iv) to ensure that the content of our websites/apps is optimised for you and for your computer or device, (v) to provide you with targeted advertising and content, and (vi) to enable you to participate in interactive functions if you wish. For example, we remember your login ID/email address or your screen name so that you can quickly log in the next time you visit our website or so that you can easily find the items you have previously placed in your shopping basket. Based on this type of information and with your consent (if required), we will also show you specific content or promotions tailored to your interests. The use of your personal data is voluntary and you will find detailed information on the option to refuse or withdraw consent, in particular in Sections 9 and 10 below. |
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Order processing We use your personal data to process and dispatch your orders, to inform you about the status of your orders, to correct addresses, to implement our loyalty or voucher programme and to carry out identity checks and other fraud detection activities. This includes the use of specific personal data and payment information. |
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Other general purposes (e.g. internal or market research, analytics, security) We use your personal data in accordance with applicable laws for other general business purposes, such as managing your account (including registration and login), conducting internal research or market research and measuring the effectiveness of advertising campaigns. We also use your personal data for the administration and operation of our communications, IT and security systems. |
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Legal reasons or merger/acquisition We are part of the Nestlé and Vitaflo group of companies. In the event that we or Nestlé or Vitaflo or its assets are acquired by or merged with another company, including through insolvency, we will share your personal data with any of our successors in title. We will also share your personal data with third parties
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On request we will provide you with more detailed information on the legitimate interests and the assessment of interests.
6. DISCLOSURE OF YOUR PERSONAL DATA
We share your personal data with the following types of recipients:
Service provider
These are external companies with whom we conduct our business (e.g. website development, data analysis, IT service providers, marketing service providers, logistics service providers, advice and consulting services, debt collection services, sales partners, file and data disposal services, etc.). Only in our name may service providers and selected employees thereof access your personal data and use it for the specific order-processing tasks that they are required to perform in accordance with our instructions, and they are obliged to handle your personal data confidentially and securely.
Third-party companies that use personal data for their own marketing purposes
Except in situations where you have given your consent, we do not send your personal data to third party companies for their own marketing purposes. Your identity will be disclosed at the time of your consent.
Third-party recipients who use personal data for legal reasons or by reason of mergers/acquisitions
We will share your personal data with third parties for legal reasons (in particular to government bodies such as courts and public prosecutors) or in the context of an acquisition or merger (see Section 5 for details).
Recipients with a corporate group reference
We are part of Nestlé and co-operate with other Nestlé and Vitaflo group companies. Personal data will only be transferred to other group companies if there is a legal basis for this and if this is necessary for one of the purposes listed above. Nestlé has concluded a group-wide agreement on the handling of personal data for this purpose.
7. STORAGE OF YOUR PERSONAL DATA
We keep your personal data only for as long as is necessary to be able to fulfil the purposes described. The periods of time required for this are checked by careful assessment, as part of which we precisely examine the necessity of data processing:
- If we process your personal data on the basis of your consent, we will do so until you withdraw your consent at the latest.
- If we process your personal data on the basis of our legitimate interests, this will take place until your legitimate refusal at the latest.
- Otherwise, we only keep your personal data to the extent necessary to fulfil our contractual and legal obligations or to preserve evidence in accordance with the legal statutes of limitations. The most important statutory retention periods can generally be between six and ten years. The legal statues of limitations can be up to thirty years.
Once the applicable retention periods have expired, we will delete or anonymise your personal data in a secure manner.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
We take all necessary measures (see below) to maintain the confidentiality of your personal data and to protect it. Please note, however, that these protective measures do not apply to information that you wish to share in public areas, such as social networks of third parties.
Persons who can access your personal data
Where necessary, your personal data will be processed by our authorised employees or persons reporting to us, depending on the specific purpose for which your personal data was collected (e.g. our employees responsible for customer service enquiries will have access to your customer data).
Measures in operating environments
We store your personal data in operating environments that apply appropriate security measures to prevent unauthorised access. We follow appropriate standards to protect personal data. Unfortunately, the transmission of information via the Internet is not completely secure.
Measures that we expect from you
It is important that you also take some responsibility for the security of your personal data. When you register for an online account, please be sure to choose a password for your account that is difficult for others to guess, and never share your password with anyone. You are responsible for keeping this password confidential and for each time you use your account. If you are using a shared or public computer, never choose to have your login ID/email address or password saved and log out of your account every time you leave the computer. You should also make use of any privacy settings or controls that we make available to you on our website/application.
Transmission of your personal data
Owing to the international nature of our business, it may be necessary for us to transfer your personal data within the Nestlé or Vitaflo group of companies and to third parties, as mentioned above in Section 6, in connection with the purposes set out in this Privacy Notice. Both the storage and processing of your personal data as described above may require that your personal data is ultimately transferred/transmitted to and/or stored at a location outside your country of residence, in particular Germany and Switzerland.
We will also transfer your personal data to countries outside the European Economic Area ("EEA") (e.g. to other companies within the Vitaflo Group), including to countries that have different data protection standards to those that apply in the EEA. We (i) have introduced standard contractual clauses approved by the European Commission to protect your personal data (and you have the right to ask us for a copy of these clauses by contacting us as described below) and/or (ii) will rely on your consent (where permitted by law), in particular insofar as there is no adequacy decision by the EU Commission.
Further information on third country transfers or copies of our measures can be obtained from the contact addresses given.
9. YOUR RIGHTS
In connection with the processing of your personal data, you have the right to information, rectification, deletion, restriction of processing and data transferability.
If you have granted us your consent, you can revoke this at any time with effect for the future. This does not affect the lawfulness of the processing carried out on the basis of the consent until withdrawal.
If we base your processing on legitimate interest, you have the right to object.
Where available, our websites have a special function that allows you to view and edit the personal data you have provided. Please note that we require our registered customers to verify their identity (e.g. login ID/email address, password) before they can access or make changes to their account information. This helps to prevent unauthorised access to your account.
We hope that we can satisfactorily answer your questions regarding the way in which we process your personal data. However, if you have any concerns, you also have the right to complain to the relevant data protection authorities.
10. YOUR CHOICES ABOUT HOW WE USE AND SHARE YOUR PERSONAL DATA
We endeavour to offer you a choice regarding the personal data you make available to us. The following mechanisms give you control over your personal data:
Cookies / similar technologies
You manage your consent via our solution for managing your cookie settings. In addition, your browser provides you with options to reject all or some cookies/similar technologies or to notify you when they are being used. Please see Section 4 above.
Advertising, marketing and sales promotion
You can state your consent to your personal data being used by Vitaflo to send you information about Vitaflo's products or services by ticking the box(es) on the registration forms. If you decide that you no longer wish to receive such communications, you may unsubscribe from receiving them at any time by following the instructions contained in each such communication.
To unsubscribe from marketing communications sent through any medium, including social networks of third parties, you can unsubscribe at any time by following the links available in our communications, logging into the websites/applications or social networks of third parties and adjusting your user settings in your account profile.
11. CHANGES TO THE DATA PROTECTION POLICY
If we make changes to the way we handle your personal data, we will update this data protection policy. We reserve the right to change our practices and this data protection policy at any time. We reserve the right to make changes and corrections to this policy. Please check this page from time to time to review it and for any new additional information.
12. ENTITY RESPONSIBLE FOR DATA PROCESSING & CONTACT
If you have any questions or comments about this data protection policy and our data protection practices, or if you wish to make a complaint about our compliance with applicable data protection laws, please contact us at: legal@vitaflo.co.uk or write to us at Suite 1.11 South Harrington Building, 182 Sefton Street, Brunswick Business Park, Liverpool, L3 4 BQ or use the address details set out in the table below. We will acknowledge and investigate any complaint about the way we handle personal data (including a complaint that we have infringed your rights under applicable data protection laws).
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ENTITY RESPONSIBLE FOR DATA PROCESSING |
RESPONSIBLE FOR |
Vitaflo (International) LimitedSuite 1.11 South Harrington Building vitaflo@vitaflo.co.uk |
All areas |