This Privacy Notice aims to give you information on how LIFEPLAN PRODUCTS LIMITED (company registration number 01843973) (“We”, “Us” and “Our”) collects and processes your personal data through your use of Our website (www.lifeplan.co.uk), including any data you may provide through Our website when you purchase a product or service or sign up to Our newsletter. We are the controller and are responsible for your personal data.
Our 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. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.
We are committed to being transparent about how We handle your personal information, to protecting the privacy and security of your personal information and to meeting Our data protection obligations under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. The purpose of this Privacy Notice is to make you aware of how and why We collect and use your personal information.
WHO WE ARE
We are a manufacturer and seller of vitamin and mineral supplements. We collect the personal data of the following types of people to allow Us to undertake Our business;
• Customers who have purchased Our products directly from Our website;
• Customers who have purchased Our products directly from Our sales team;
• Retailers, wholesalers and distributors who purchase Our products;
• Contract manufacturing customers;
• Export partners;
• Supplier contacts who support Our services;
• Employees, consultants, temporary workers; and
• Referees and Emergency contacts
FIND OUT ABOUT AND UPDATE YOUR INFORMATION
If you have any questions about this Privacy Notice or Our privacy practices, please contact Our Data Protection Officer in the following ways:-
- By email at email@example.com
- By post for the attention of the Data Protection Representative, Lifeplan Products Limited, 1 Elizabethan Way, Lutterworth LE17 4ND.
The accuracy of your information is also important to Us. If you change contact details or if you believe that any of the other personal information We hold is inaccurate, incomplete or out of date, please contact us by emailing firstname.lastname@example.org, by post for the attention of the Customer Care Team, Lifeplan Products Limited, 1 Elizabethan Way, Lutterworth LE17 4ND, or by telephone on 01455 556281 and ask to speak with our Customer Care Team.
INFORMATION 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 title, full name, date of birth and gender (if you choose to provide this).
· Contact Data includes billing address, delivery address, email address and telephone number(s).
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from Us.
· 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 Our website.
· Usage Data includes information about how you use Our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from Us and Our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this Privacy Notice.
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.
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, when We provide you with goods or services but We cannot contact you if there are issues with your order if you fail to provide your email address or phone number).
Sometimes We might ask for information that is useful for Us to know but it not required by law or a contract. When this is the case, We will make it clear by making it as optional. You do not have to provide such information to Us.
HOW WE COLLECT YOUR DATA
We use different methods to collect data from and about you including through:
• Direct interactions. You may give Us your Identity, Contact and Financial Data by placing orders with Us or by corresponding with Us by post, phone, or email.
USING YOUR PERSONAL DATA
We will only use personal information where the law allows Us to. Most commonly, We will use your personal data in the following circumstances:-
• To fulfil a contract We have with you; or
• When it is Our legal duty; or
• When it is necessary for Our legitimate interests and your interests and rights do not override those legitimate interests; or
• When you consent to it.
A 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 data for Our legitimate interests. We do not use your personal data 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).
Apart from the circumstances set out above, We will not disclose your personal information to any third parties without your consent, unless We are satisfied that they are legally entitled to the information.
In particular, We will not:
• Sell your personal information to third parties; or
• Share your personal information with third parties for marketing purposes (unless you have given your consent for Us to do so).
PURPOSE OF USING AND PROCESSING YOUR DATA
We set out below various circumstances in which We may use or process your personal data and the legal bases upon which We rely on to do so:
|Purpose/activity||Legal basis for using and processing your data|
Account administration purposes, for example:
To verify your log in details;
To process your purchases.
This is necessary for Our legitimate interests to ensure that our customers receive an appropriate level of service. We will use your Identity, Contact and Transaction Data to achieve this purpose.
|To send notifications or account information to you by email.||This is necessary for Our legitimate interests to ensure that Our customers receive an appropriate level of service. We will use your Identity, Contact and Marketing Data to achieve this purpose.|
|To send you general marketing about Our products.||We shall only do this where you have provided consent and have opted-in to receive direct marketing via the preference setting in your Lifeplan account. We will use your Identity, Contact and Marketing Data to achieve this purpose.|
WITHDRAWAL OF CONSENT
If you have provided your consent for Us to process your personal information, you have the right to withdraw your consent at any time. This will not affect the legality of Our consent-based use before you withdrew your consent.
If you wish to withdraw your consent, you must make the request in writing addressed to Our Data Protection Representative using one of the methods set out in the FIND OUT ABOUT AND UPDATE YOUR INFORMATION section of this Privacy Notice.
We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, this includes satisfying Our contract with you to provide Our products and services. We may retain your personal data for a longer period in the event of a complaint, however this period shall never exceed six years.
To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may use your personal data to tell you about Our relevant products, competitions and offers. This is what We mean when We talk about ‘marketing’. We may also use your data to help create a profile to find potential customers like you.
We will send you marketing based on what you tell Us about yourself, data We collect when you use Our services, and using information from third parties We work with. We use this information to get a view on what We think would interest you the most.
We will only send you marketing messages if We have either your consent (when you opt-in) or a legitimate interest.
You can ask Us to stop sending you marketing messages by contacting Us at any time by clicking ‘unsubscribe’ at the bottom of any marketing email or updating your preferences in your online account.
Whatever you choose for marketing, you will still receive service or contractual messages.
TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA ("EEA")
We will not transfer your data to countries outside the European Economic Area.
YOUR LEGAL RIGHTS
You have the rights 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 Our legal obligations. 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 processing of your personal data where We are relying on a legitimate interest 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:
· If you want Us to establish the data's accuracy;
· Where Our use of the data is unlawful but you do not want Us to erase it;
· 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
· 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.
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
We and Our third party suppliers use reasonable and up to date security methods to keep your data secure and to prevent unauthorised or unlawful access to your information.
If you have any issues with Our processing of your personal information and would like to make a complaint, please do not hesitate to get in touch using the contact information set out at the FIND OUT ABOUT AND UPDATE YOUR INFORMATION section above.
If you would like to make any further complaint, please contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or telephone 0303 123 1113.
This Privacy Notice explains what happens to the personal information that We collect from you whenever you use Our website, place an order, or you get in touch with Us, whether via Our website or by email, telephone, or post.
We may update this privacy notice from time to time so please check with Us occasionally to ensure that you are happy with any changes. We will notify you by email when the Privacy Notice changes.