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Europe/London
Last updated: March 2023
Comvita UK Limited ("Comvita, “we”, “our”, “us”) takes the privacy and security of personal data very seriously.
We ask that you read this Privacy Notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
This Privacy Notice applies (unless a different notice is displayed) to the processing of personal information collected by us in the usual course of business, including when you visit our website at Comvita.co.uk ("Website") or interact with us on social media platforms including, but not limited to Facebook and Twitter (collectively “Social Media”).
1.1 Comvita UK Limited is a wholly owned subsidiary of Comvita Limited, a company domiciled in New Zealand, and listed on the New Zealand Stock Exchange (“NZX”). We provide a full range of health, wellness and beauty products including Manuka Honey, Propolis and Olive Leaf Extract.
1.2 Comvita is the controller of the personal information that we process for the purposes described in the Privacy Notice.
Information you provide to us
2.1 There are various ways we may interact with you over the Website or our Social Media pages. Comvita collects the following information about you when you use the Website (including Comvita’s Social Media pages):
2.2 We may use this information in the following ways:
2.3 We do not collect any ‘Special Categories of Personal Data’ about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Information we collect automatically
2.4 When you visit our Website or interact with us on Social Media, we use cookies and similar technologies to automatically collect certain information from your browser or device. This may be considered "personal data" under data protection laws.
2.5 We may collect information about your computer including your IP address, operating system and browser type for system administration and to report aggregated information as well as site tracking information.
2.6 For more information about cookies please see below and read our Cookie Notice.
2.7 Cookies and similar technologies. 'Cookies' are small pieces of information that are stored by your browser on your computer's hard drive. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that. For further information about our use of cookies or other similar technologies, your choices regarding the use of cookies, and how you can block certain cookies in connection with our Marketing Activities, please read our Cookie Notice.
3.1 We may disclose your personal information as follows:
3.2 We only allow third parties to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. One way we achieve this is by placing contractual obligations on third parties governing the use of personal data that we provide them with.
3.3 We will share personal information with law enforcement or other authorities if required by applicable law.
4.1 Our legal basis or collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
4.2 However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
4.3 If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
4.4 If we collect and use your personal information in reliance on our legitimate interests, this interest will normally be to operate our Website and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, or improving our Website. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
4.5 If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “CONTACT” section below.
5.1 You will only receive marketing communications from us and/or third parties if you have consented to this when you provided your contact details to us (or if you have otherwise submitted your consent to us for these purposes).
5.2 You have the right to ask us not to use your personal data for marketing purposes. You can request that you stop receiving information from us at any time by contacting us at the details set out below (please see section 14 “CONTACT”).
6.1 All information you provide to us is stored on our secure servers and those of our group of companies, service providers and agents.
6.2 We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We use strict procedures and security features to prevent unauthorised access.
6.3 Agents or contractors who, while providing services to Comvita, have access to information which you give to us are required to keep that information secure and confidential and are not permitted to use it for any purpose other than to carry out the services which they are performing for Comvita.
7.1 As set out in section 6 above, information may be sent electronically to servers outside of the country where you originally entered the information. In addition, that information may be used, stored and processed outside the country where you entered that information. While there is a risk that countries to which information is transferred will not be subject to an information protection regime as rigorous as that of the UK or the European Economic Area (EEA), we will always take steps to ensure that your information is treated securely and adequately protected in accordance with this Privacy Notice.
7.2 Where information is transferred outside the UK and/or the EEA, e.g.:
8.1 If you choose to create an account, we will keep your personal information for as long as your account is open. If you don’t have an account, or choose to close your account, we will keep some of your information until 7 years have passed since we last provided product for you.
We consider 7 years to be an appropriate retention period because it is as long as is necessary for us to:
8.2 We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Notice.
8.3 When it is no longer necessary to retain your personal information, we will delete or anonymise it.
8.4 In some circumstances you can ask us to delete your data: see section 11 “YOUR RIGHTS”.
9.1 We do not disclose personal information about individuals to our advertisers or sponsors, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' and sponsors’ wishes by displaying their advertisement to that target audience.
10.1 We work with trusted third parties, including social network sites like Facebook, Twitter, YouTube and with application developers who specialise in social media so we can connect to your social networks. All these companies operate third party sites. We provide access to our Social Media to third parties and business partners so we can generate interest in our products and services among members of your social networks and to allow you to share product and service interests with friends in your network. The Website may also contain links to and from other websites.
10.2 We cannot control how your data is collected, stored, used or shared by these third party sites or to whom it is disclosed. If you follow a link to any of these websites please note that we are not responsible for the privacy practices or the content of such websites save as expressly set out herein in relation to Comvita and the information practices of those websites are not covered by this Privacy Notice. Please be sure to review the privacy policies and privacy settings of these third parties to make sure you understand the information they are sharing. If you do not want a third-party site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information.
11.1 You may have the following rights with regard to the personal information we process about you, which you can exercise free of charge:
Access - The right to be provided a copy of your personal information and check that we are lawfully processing it.
Rectification - The right to require us to correct any mistakes in your personal information, though we may need to verify the accuracy of the new data you provide to us.
To be forgotten - The right to require us to delete your personal information – where there is no good reason for us continuing to process it or where you have successfully exercised your right to object to processing (see below). 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.
Restriction of processing - The right to require us to restrict processing of your personal information in the following scenarios:
Data portability - The right to receive the personal information you provided to us in a structured, commonly used and machine-readable format and / or to transmit that data to a third party, in certain situations. 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.
To object - The right to object
Not to be subject to automated individual decision-making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly affects you.
To withdraw consent at any time - This only arises where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing before you withdraw consent.
11.2 If you would like to access any of these rights, please email or write to us at the details provided below (see section 14 “CONTACT”) explaining what right you want to exercise and the information to which your request relates. Please be sure to provide enough information to identify you (e.g. your full name, address, email address and/or any order reference number). Please also provide us with proof of your identity and address (for example, a copy of your passport or recent utility bill).
12.1 We hope that we can resolve any query or concern you may raise about our use of your information; however, in the event that we are unable to do so, you have the right to complain to the data protection authority. The supervisory authority in the UK is the Information Commissioner, who may be contacted online at WWW.ICO.ORG.UK/CONCERNS or alternatively by telephone on 0303 123 1113.
13.1 We may occasionally modify our Privacy Notice. When you use our Website or interact with us, you should check the date of this Privacy Notice (which appears at the top) and review any changes since the last version.
13.2 If we make any material changes to this Privacy Notice, we will notify you either via email or prominently posted a notice on the Website of such changes.
14.1 If have any questions, comment or requests regarding our Privacy Notice or our data protection activities, please email [email protected] or write to us at Comvita UK Limited, Box 220, 5 High Street Maidenhead, SL6 1JT.
14.2 Please contact us at [email protected] with any request different to our standard policy.
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