Introduction

Welcome to the probio7.com’s privacy notice.

probio7.com respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information when you visit our website and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Importance Information and Who We Are

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how probio7.com collects and processes your personal information through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Forever Young International Ltd.

Forever Young International Ltd. is the controller and responsible for your personal information (collectively referred to as ”probio7.com”, “we”, “us” or “our” in this privacy notice).

probio7.com is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Forever Young International Ltd so when we mention ”probio7.com”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Forever Young International Ltd. responsible for processing your data.

CONTACT DETAILS

Our full details are:
Legal entity: Forever Young International Limited.

Contact email address: info@probio7.com

Postal address: Forever Young International Ltd. Units 13 and 14 Nelson Trading Estate The Path, Merton SW19 3BL, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 25th May 2018.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You can update your information at any time by amending your personal information within Your Details section of My Account at www.probio7.com or alternatively – Contact us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes a billing address, delivery address and email address.
• Transaction Data includes details about payments made when purchasing through our site.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
• Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Site, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  
  

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with delivery of goods). In this case, we would be unable to supply you.

3. How is Your Personal Data Collected

Direct interactions. You may give us your Identity, Contact, Transaction or Financial Data by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:

• Create an account on our Site;
• Subscribe to our newsletter
• Submit an enquiry about a transaction via our Site;
• Enter a competition, promotion or survey;
• Give us some feedback;

Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies. Please see our Cookie Policy for further details. As you navigate our Site, we may collect Usage Data, Profile Data and Marketing and Communications Data as specified by you from time to time.

Third parties or publicly available sources.

We may receive personal information about you from various third parties as set out below:

Technical Data from the following parties:

1. Analytics providers such as Google Analytics and Google DoubleClick based outside the EU;
2. Advertising networks such as Google AdWords Network based outside the EU;
3. Social Network providers such as Facebook based outside the EU;
4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU, SAGE Pay, ROYAL MAIL, MyHermes based inside the EU.
   Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
   
   

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Without sharing your information with our trusted and accredited partners (MyHermes, Royal Mail, PayPal, Sage Pay), we would not be able to process or delivery any orders placed with us.

Data collected by this site for customers who do not have a login account is used to:

(a) Take and fulfil customer orders.

(b) Administer and enhance the site and service.

(c) Only disclose information to third-parties for goods delivery purposes.

Data collected by this site for customers who have a login account is used to:

(a) Take and fulfill customer orders

(b) Administer and enhance the site and service

(c) Issue a unique identifier (e.g. customer login)

(d) Monitor customer account status beyond that required for individual purchases

(e) Only disclose information to third-parties for goods delivery purposes

5. Purposes for Which We will Use Your Information

In general terms, we use the personal information we collect to help probio7.com better understand you and to enable us to personalise your experience with probio7.com, including offers, promotions and services to meet your needs.

We use your information to:

• personalise our services, offers and promotions to you and provide you with a personalised experience on our site;
• process your online orders;
• offer you site content that includes items that you might like and to keep track of your basket;
• contact you about your account and tell you about important changes to probio7.com;
• provide, develop and improve our products and services;
• provide you customer service;
• manage promotions, competitions, customer surveys and questionnaires;
  and check and verify your identity, and prevent, mitigate or detect and investigate crime, fraudulent or illegal activities;
• process purchases, payments, customer support and order fulfilment.

MARKETING

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You can view and make certain decisions about your personal information use at any time at your account, or by e-mailing or contacting our Customer Services team.

In summary:

• Amend your options within the “Your Details” section of “My Account” on the Website;
  click on the “unsubscribe” link on the bottom of any of our e-mails to opt of email communications;
• Write to us at Forever Young International Ltd. Unit 13 and 14 Nelson Trading Estate The Path, Merton SW19 3BL  United Kingdom.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

THIRD-PARTY MARKETING

We will never sell your personal data to any company outside Forever Young International Ltd for marketing purposes. As referred to above, we may share your Contact Data with third party social media publishers, such as Facebook in order to ensure our marketing is targeted at and relevant to probio7.com members.

OPTING OUT

You can ask us to stop sending you marketing emails at any time by clicking unsubscribe on any email marking material.

COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site will become inaccessible or not function properly. Please see our Cookie Policy.

6. Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

7. Data Retention

HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In addition, this includes that we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies.

When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data.

In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please see below to find out more about these rights and access the request forms should you want to make any of these requests:

If you wish to exercise any of the rights set out above, please send a request to us to the e-mail or postal address.

YOU HAVE THE RIGHT TO:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• (a) if you want us to establish the data’s accuracy;
• (b) where our use of the data is unlawful but you do not want us to erase it;
• (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests.

We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting help@probio7.com

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Forever Young International Ltd who act as joint controllers or processors within the EEA and who provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

Service providers acting as processors based in the EEA who provide IT, system administration services, payment providers to facilitate purchases, fulfilment providers to facilitate order management, packaging and delivery and marketing and communications services providers in order to personalise your experience and communicate with you.

Professional advisers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators, law enforcement bodies and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances and otherwise in defence of legal claims.

Market researchers, fraud prevention agencies and analytics providers.

10. Cookies

WHAT ARE COOKIES?

Cookies are small data files that are stored on our server. When you visit our WebSite a copy of the cookie is stored on your computer or other devices when you visit our WebSite. When you visit our WebSite again our server will recognise your computer or other devices through the cookie is placed on it last time you were on our WebSite.

We do not sell advertising space so we do not allow advertising networks to place cookies on our WebSite. We do not trade personal data.

We use cookies for the following reasons only:

To identify you as you travel around our site and to monitor your journey and record sales. This enables us to identify issues and improve our customer journey.

To provide site usage information, which together with purchase information, will further help us improve and develop the Product(s).

To ensure that your order is processed correctly.

You may change your website browser settings to reject cookies.

To learn how to disable cookies or opt out of their usage please visit www.aboutcookies.org.

Please note, however, that some cookies are essential in order to shop on the WebSite and in the event you do reject cookies this may impair the functionality of the Website.