Effective Date: 11th March 2019
For the purposes of the Data Protection Act 1998 (the "Act") and any applicable legislation replacing or amending the Act, We are the Data Controller.
As part of our commitment to privacy, We are a member of the Network Advertising Initiative ("NAI") and participate in the Digital Advertising Alliance ("DAA") self-regulatory program. We adhere to each of their codes of conduct and principles and you can learn more at the NAI about interest based advertising and how to opt out of receiving targeted advertising from any of their members.
2 What Personal Information do we collect?
2.1 Information you actively provide to us
We collect personal information that you actively submit to us during your use of our websites or services. For example:
- when you register on one of our websites or for our services, you may provide us with certain personal information including your name, email address, screen name, password and demographic information such as data of birth; and
- you may provide us with information in the course of email, customer support interactions and surveys.
Different websites operated by us may ask for different types of your personal information. You can choose not to provide us with certain information, but this may stop you from gaining access to a service or limit the features that you can use on our websites. For more information, please see the "How We Use Your Information" section of the Policy below.
2.2 Personal Information you passively provide to us and third parties during your use of our websites
As you use our websites, your personal information may also be passively collected by us and our partners through the use of:-
- Cookies - Small text files containing a string of characters used to identify an Internet browser.
- Statistical IDs - A probabilistic method of identifying a device based on a set of its characteristics that have a reasonable likelihood of being unique in aggregate (e.g. using a hash of the IP address, user-agent string and screen resolution).
In order for us and our partners to deliver personalised information, services, tools and advertisements, the information that we collect may include IP address, non-precise geographical location, browser details, operating system, search terms, time spent on sites, ads viewed and intent signals (inferred information based on likely interests associated with a website/URL).
Intent signals do not include Sensitive Information (racial or ethnic origin, political opinions, religious beliefs or similar, union membership, physical or mental health conditions or sexual life) though may include non-sensitive general health related information such as skin-care products and dietary supplements.
2.3 Information we receive from third parties
We may also receive your personal information from third parties who operate websites and/or provide services that you use on such third-party websites, where you have given such third parties consent for them to collect and share your personal information. This may consist of personal information that you have actively provided to such third parties such as your name and email address and/or personal information that you have passively provided to such third parties in the course of your use of their websites and/or services. Such personal information is collected by such third parties and is shared by them with us in accordance with such third parties' privacy policies and practices.
2.4 Information you passively provide to us during your use of third party websites
Where you use third party websites which deploy our cookies, pixels, beacons, log files and other technologies, your personal information may also be passively collected by us during your use of such third-party websites in accordance with their privacy policies and practices.
2.5 Your consent to our collection and use of your Personal Information
By using our websites or the websites of third parties from which our services are available, you consent to our collection and use of your personal information as described in this Policy. If we change the way we collect, use or disclose your personal information we will publish an updated version of this Policy. Your continued use of our websites or the websites of third parties from which our services are available after this Policy has been amended shall be deemed to be your continued acceptance of the terms of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.
3 Third party websites and services
Your browsing and interaction on any other website or your dealings with other third party service providers, is subject to that website's or third party service provider's own rules and policies. We do not monitor, control, or endorse the information collection or privacy practices of such third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
4 How we use your Personal Information
We will use your personal information in the ways described below.
4.1 To provide our services to you
We use your personal information as necessary or appropriate for our business purposes including to:
- respond to inquiries or requests that you direct to us;
- fulfil your requests for our services; and
- send communications and administrative emails to you about our website or our services.
- allow personalised advertising to be served to you by Us or Our Partners.
- provide anonymised reporting to Us and Our Partners.
Where you have provided us with the appropriate consents, we may send you marketing materials about products or services offered by us and/or products or services offered by our group companies. In addition, where you have provided us with the appropriate consents, we may also pass your Information to one or more of our group companies or other selected third parties for marketing purposes.
4.3 Data aggregation, analytics and profile creation
We may combine your information that we receive from third parties (including one or more of our group of companies) with information that we have collected from you to provide us and our third party partners with a more detailed profile of you.
We may also analyse your personal information to draw inferences and create profiles about your personal preferences and behaviours. We may then use such personal information to verify other personal information about you (e.g., verify your contact details) and for the other purposes described in this Policy. This information may be collected by cookies, web beacons or other technology for example which collects information from your web browser. The information may tell us about your activity on our sites or the sites in order to improve our service and/or to help create a profile of you in order to deliver personalised advertising.
4.4 Personalised Advertising (interest based advertising, retargeting and cross platform targeting)
(a) Served by us
We may use your information (including profile data) to serve you with advertising, which is relevant to you, in different domains and applications on our websites and the websites of third parties. Sometimes we may use health related segments such as an inferred interest in certain health conditions that do not require a prescription such as allergy medications.
(b) Served by third parties on our websites
(c) Served by third parties on third party websites
We may provide your information (including profile data) to third parties who may then use it in combination with personal information that they have collected from you to serve you with relevant advertising on third party websites.
(a) On our website
(b) On third party websites
5.2 Personalised Advertising
You may opt-out of future Personalised Advertising on all of our websites and our Partner websites by clicking here. If you opt-out, in addition to deleting your existing profile, we will place a cookie on your browser that identifies you as having opted-out and if you use several browsers or devices you will need to opt-out on each. Similarly, if you delete the opt-out cookie you will need to opt-out again to maintain your preferences. Alternatively, you can opt-out via www.networkadvertising.org/choices.
6 How we may also disclose your Personal Information to third parties
We may share your personal information with third parties as specifically approved by you or under the circumstances described below.
6.1 Disclosure for legal reasons
We may disclose your personal information if we are under a duty to disclose or share your personal information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers, our group companies or others.
We use a number of third party organisations to help provide a professional service to our customers (i.e. fulfilment bureaus, call centres, and website designers). These organisations act as data processors and are strictly controlled in how they may/may not use your Personal Information and we remain responsible for the protection of your Personal Information that we disclose to such organisations.
6.2 Changes to our Company
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
7 Updating and control of your Personal Information
There are a number of ways in which you can control the collection, use, and sharing of your Personal Information.
7.1 Can I find out what Personal Information you hold about me?
You have the right to request a copy of the personal information that we hold about you. You can contact us at email@example.com.
7.2 Updating your Personal Information
If your personal information has changed or if you no longer wish to receive marketing communications from us then you can contact us at firstname.lastname@example.org.
Please note that:
- we may still retain your personal information, including that used for Ad or Personalised Ad delivery, where we have a legitimate reason to do so or where it is lawful for us to do so; and
- we are not responsible for updating or removing your personal information held by third parties.
8 Where We Store Your Information
The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area. Your information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal information to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy and applicable law.
Security of your Personal Information
We follow appropriate security procedures in the storage and disclosure of your personal information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal information to comply with the same. However, unfortunately, the transmission of information via the Internet is not completely secure. So, we cannot ensure the security of your personal information transmitted via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your personal information, except to the extent we are required to accept such responsibility by law.
Our products and services are not for or intended to be used by Children (where a Child is defined as under the age of 16) and we do not knowingly collect personal information from Children. If you notify us that we have received personal information from your child without your consent we will use reasonable efforts to remove that information from our Platform
10 Data Retention Period
We retain the data collected for our products and services for the purpose of personalised advertising for up to thirteen months from the date of the last user interaction. Aggregated or de-identified data is used for reporting and analysis, and may be retained for a further two years.
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