Privacy Policy
VITAL PROTEINS
respects the privacy of every person who interacts with VITAL PROTEINS and we
are committed to ensuring high standards of data protection compliance in
everything we do.
1. WHAT IS THE PURPOSE OF THIS NOTICE?
This privacy notice applies to all
services and activities we provide across the web, social media, apps and
elsewhere, including our ecommerce store (the “VITAL PROTEINS Services”). It
explains our approach to how we use any personal information that is provided
to or collected by us in connection with your use of the VITAL PROTEINS
Services or any other interaction you have with VITAL PROTEINS.
This
privacy notice also sets out the legal basis on which we are permitted to
process your personal information, your rights in respect of our use of your
personal information, how you can verify what personal information is collected
by us, and how you can request that we delete, update or transfer it.
This
privacy notice is intended to assist you in making informed decisions when
using the VITAL PROTEINS Services. Please read it thoroughly and note that it
should be read in conjunction with our Terms and Conditions.
2. WHO ARE WE?
The VITAL PROTEINS Services are operated by VITAL PROTEINS Limited (“VITAL PROTEINS”, “we” “us” or “our”).
VITAL PROTEINS Limited is the data controller responsible for your personal information. VITAL PROTEINS Limited is registered at the UK Information Commissioner’s Office with registration number: ZA114883
VITAL PROTEINS Limited is an English company with registered company number: 09125906 and whose registered address is 6th Floor One London Wall London EC2Y 5EB.
3. HOW TO CONTACT US?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
• Phoning us on 08008807034
• Messaging us through our Help Centre.
4. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT USERS AND VIEWERS OF VITAL PROTEINS AND HOW DO WE COLLECT IT?
Personal information may be collected
from you in the following ways (see in the following section for information on
how and why we use the information):
Information
you voluntarily provide to us directly.
We
collect and maintain personal information that you voluntarily submit to us during
your use of the VITAL PROTEINS Services or other contact with us. For example
when you register, sign up for a newsletter, enter a survey or competition,
submit content contributions, post comments or buy merchandise through our
sites.
This may include:
• Name;
• Email Address;
• Address;
• City or Country;
• Date of Birth;
• Gender;
• favourite teams etc;
And may include
information in the content you submit:
• Your image or likeness (or that of others who also appear) in the content you
submit;
• Other information about yourself (or that of others who also appear) in the
content you submit;
• Other information about yourself (or that of others who are also mentioned)
in the messages you send to us.
INFORMATION YOU VOLUNTARY PROVIDE TO US THROUGH SOCIAL MEDIA LOG IN.
We collect and maintain personal information from you social media profile that
you voluntarily agree to be provided to us when you register or sign up, or
take part in a survey etc using our social media (such as Facebook) login functionality.
This may include:
• Name;
• Date of Birth;
• Gender;
• Social media ID;
INFORMATION WE COLLECT THROUGH YOUR USE OF THE VITAL PROTEINS SERVICE
We collect, through our use of cookies or other technologies, information about
your use of and navigation around the VITAL PROTEINS Services including the
emails we send you, including information regarding your mobile device or the
computer hardware and software used to access the VITAL PROTEINS Services.
This may include
the following:
• IP address of device(s) used;
• browser type;
• operating system and device type;
• approximate location (e.g. London);
• access times and dates;
• referring website addresses;
• navigation around the site;
• links followed, including in emails;
• time spent on pages or viewing content;
• types of content viewed and shared.
Please see the Data Analytics, Insight and Profiles section below and our
Cookie Section below for further information.
INFORMATION WE RECEIVE FROM THIRD PARTY DATA SOURCES AND BRAND PARTNERS
We may also combine information that we hold about you with information that we
obtain from third parties including brand partners and data aggregators. This
information may be used to indicate your likely interests so we can provide a
more relevant service to you. We will always ensure that the provider of the
information has relevant permission and legal basis to share such information
with VITAL PROTEINS.
Please see the Data Analytics, Insight and Profiles section below for further
information.
INFORMATION WE RECEIVE FROM THIRD PARTY SERVICE PROVIDER PARTNERS
We may use third parties to provide additional services such as ecommerce,
ticketing or other retail or merchandise functionality. Normally you will be
interacting and contracting directly with such third parties in this situation.
As part of this subcontracted solution we will receive information back from
our partners relating to your purchases. This may include your name and email
address and other information such as the category of item purchased or club,
brand or event to which it relates. This information will be by used by us to
indicate your likely interests so we can provide a more relevant service to
you. Please also see the section below on “VITAL PROTEINS Store / ecommerce”
for more information on the on-site store.
Please see the Data Analytics, Insight and Profiles section below for further
information.
5. HOW DO WE USE THE PERSONAL INFORMATION OF USERS AND VIEWERS OF VITAL PROTEINS?
We use the personal information we
collect from or about you for the following purposes:
Provision
of the VITAL PROTEINS Service.
We need
to use your information to log you in, verify who you are, ensure you get the
service that you have registered for and otherwise to provide you with our
services.
What is our legal
basis for this?
It is necessary for the performance and fulfilment of the contract between us
to provide you with services for which you have registered.
Sending you newsletters or other communications (from VITAL PROTEINS) for which
you have subscribed.
Where you have given your consent we use your personal information to send you
newsletters and other marketing materials about VITAL PROTEINS products and
services which we think you might be of interest to you.
What is our legal
basis for this?
We rely on your consent to be able to do this – given at the time that you
request the newsletter or other marketing.
Running surveys, competitions and/or promotions.
We may collect and use your personal information in connection with any survey,
competition and/or promotion that you enter.
What is our legal basis for this?
It is in our legitimate interest to use your personal information in such a way
to operate the survey, promotion and/or competition. Please note that we will
only send you marketing communications promoting a competition or survey with
your consent.
Data Analytics,
Insight and Profiles.
We analyse your personal information including that which we observe about you
from your interactions with our VITAL PROTEINS Service, our email communications
to you and/or the products and services you may have purchased or viewed,
including any third party information we have sourced as detailed above.
This information is used to create profiles and insights about viewing and
usage habits across our services. By using this information, we are able to
measure the effectiveness of our content and how visitors use VITAL PROTEINS
Services. This allows us to learn for example what content and pages are most
attractive to our users, which parts of our services are the most interesting
and what kind of information our users like to see.
We also use this information to help us with the selection and creation of
future content and services.
We also use this information to help us with the selection and presentation of
relevant advertising messages to you.
We also use this information for social media marketing purposes (see the
sections below for further details).
What is our legal
basis for this?
Where your personal information is completely anonymised, we do not require a
legal basis to use it as the information will not constitute “personal
information” that is regulated under data protection laws. However, our
collection and use of such anonymised personal information may still be subject
to other laws where your consent is required. Please see our Cookie Section
below for further details.
Where your personal information is not in an anonymous form, it is in our
legitimate interest to use your personal information in such a way to ensure
that we provide the very best content and services to you and our other users.
Social media remarketing.
We use
information that we observe about you from your interactions with VITAL
PROTEINS Services, our email communications to you and/or with our content and
services (see the Data Analytics, Insight and Profiles section above for more
details of the information collected and how it is collected) to provide you
with personalised content or advertising on social media channels operated by
Facebook and/or Google where you are a registered user of such services.
We do this using Facebook Custom Audiences and/or Google Customer Match
respectively. Please note that such activity is also subject to the privacy
choices you have elected to make on such services.
To do this we share your encrypted email address with Facebook and/or Google
under the terms of their Facebook Custom Audiences and/or Google Customer Match
services respectively. We do not permit them to use your information for any
other purposes.
Where you are a
registered user of Facebook, or of a Google service, we will use your email
address in an encrypted format to enable Facebook and Google to find other
registered users of their services (to whom to serve adverts) that share
similar interests to you based on:
• information that we observe about you from your interactions with our
services, our email communications to you and/or with our content and services
see the Data Analytics, Insight and Profiles section above for more details of
the information collected and how it is collected); and
• the information Facebook and/or Google hold about you.
We do this using Facebook Custom Audiences and/or Google Customer Match
respectively. Please note that such activity is subject to the privacy choices
you have elected to make on such services. Please note that Facebook and Google
do not use your information for anything other than suggesting to us similar
types of users on their services to whom to serve adverts; and we do not use
your information to make any decision about you.
Publishing
content you provide.
If you provide us with any content (e.g. photos or videos) that you wish to
feature on our services, we will collect certain personal information from you
when you provide the content and will use it in connection with sharing the
content you have provided. The content may also contain your personal
information, or that of others who also appear or are mentioned, in the form of
images or other information that may identify you or them.
What is our legal basis for this?
It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered. When you submit your content for these purposes we will also take that as consent to use your content and the personal information in this way and confirmation that you have the consent of any others appearing in the content.
It is also in our legitimate interest to use your personal information in such a way to operate the service.
Service Administration.
We may also use your personal information to:
• help improve the VITAL PROTEINS Services; and
• contact you to answer any queries you may have sent to us.
We may share your
personal information with third party brands on an anonymised basis. e.g.
details on the type of audience that engaged with our campaigns. We will not
share an information that is not anonymised, nor allow them to market to you
without your consent.
What is our legal
basis for this?
It is in our legitimate interests to share your personal information in such a
way to ensure that we provide the very best service we can to you.
Business administration, record keeping and legal compliance.
We use your
personal information for the following business administration and legal compliance
purposes:
• to comply with our legal obligations;
• to enforce our legal rights;
• protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by
another company, or sale of all or a portion of our assets.
Use in this way may involve us sharing your personal information with
professional advisers such as lawyers and accountants and/or governmental or
regulatory authorities.
What is our legal
basis for this?
It is in our legitimate interest to ensure that we keep our records up-to-date
and use them in connection with a business transition, enforce our legal
rights, or to protect the rights of third parties. Otherwise, it is our legal
obligation to use your personal information to comply with any legal
obligations imposed upon us or other laws regulations that we are subject to.
6. VITAL PROTEINS STORE / ECOMMERCE
Our on-site ecommerce store is run for us currently by The Hut Group. You can find their details in the Terms and Conditions on the store section on the site.
Whilst they
operate the store, and are the merchant of record responsible for the sale of
goods to you, VITAL PROTEINS remain the data controller in relation to any
personal data you submit or we collect through the store, and The Hut Group are
merely the data processor acting on our behalf and strictly on our
instructions.
The Hut Group (as data processor) will have access to you data solely in
relation to fulfilling the transaction, processing your purchase, sending you
the goods you have purchased and otherwise dealing with customer queries and
other store related matters. They will not use your data for any other
purposes.
VITAL PROTEINS (as data controller) will otherwise collect, use and share your
data that relates to you ruse of the ecommerce store, in accordance with
sections 4 and 5 above and the other parts of this Privacy Notice.
7. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT OTHER PEOPLE, HOW DO WE
COLLECT IT, AND HOW DO WE USE IT?
Ø Creator Network
We collect and
maintain personal information about potential and current members of our
Creator Network.
Initially we source this information from research of social media and
following your activity and posts. We may keep a record of your name, social
media handle and a description of your activity and posts. We do this to assess
if we might be interested in contacting you to join our network.
If you join our network we collect and maintain any other information that you
give us and details about the activity we may work on together.
It is in our legitimate interest to collect and process your information in
this way to improve our service and grow our network, once in our network, it
is necessary for the performance and fulfilment of the contract between us.
Ø Distribution Network
We collect and maintain personal information about potential and current distributors of our content.
Initially we
source this information from research of social media and following your
activity and posts. We may keep a record of your name, social media handle and
a description of your activity and posts. We do this to assess if we might be
interested in contacting you to distribute our content.
We further collect and maintain any other information that you give us for the
purposes of distributing our content, and details about the activity we may
work on together.
It is in our legitimate interest to collect and process your information in
this way to improve our service and grow our distribution activity, once in our
team, it is necessary for the performance and fulfilment of the contract
between us.
8. HOW DO WE OBTAIN YOUR CONSENT?
8.1 Where use of your personal
information by us requires your consent, you may provide such consent:
• at the
time we collect your personal information by following the instructions we
give; or
• by
informing us using the contact details set out in this privacy notice.
9. USE OF COOKIES
9.1 The VITAL PROTEINS Services
may use certain cookies and other technologies of which you should be aware.
WHAT ARE COOKIES?
Cookies and similar technologies are very small text documents or pieces of
code, which often include an anonymous unique identifier. When you visit a
website or use a mobile application, a computer asks your computer or mobile
device for permission to store this file on your computer or mobile device and
access information from it. Information gathered through cookies and similar
technologies may include the date and time of visits, preferred country of
residence and how you are using the particular website or mobile application.
Cookies are used by us as part of our website and they are also used by some of
our third party partners.
For more details on cookies and similar technologies please visit All About
Cookies. For the purposes of the remaining sections of this Cookie Policy we
will refer to all technologies using the above features as “cookies”.
CONSENT TO OUR
USE OF COOKIES
By using the website you acknowledge that we may store and access cookies on
your computer or other device including consenting to certain cookies that are
not essential to the operation of our website but allow us to provide
additional functionality or to gather additional information about your use of
our website. You are not obliged to give consent to our use of non-essential
cookies.
If you wish to block or delete cookies, or you would like to withdraw consent
to our use of non-essential cookies, you can find out how to do so below.
WHAT DO WE DO
WITH COOKIES?
Essential Cookies
We use cookies where they are essential for the operation of the website, for
example to remember that you are signed in to the website.
Session Cookies
We use cookies to allow the website to uniquely identify your browsing session
on our website, which allows us to coordinate this information with data from
our website server.
Analytics Cookies
We use “analytics” cookies. These, along with other information, allow us to
calculate the aggregate number of people using the website and which features
of our website are most popular.
We use this information to improve the website. We do not generally store any
information that you provide to us in a cookie.
Social Media
We use cookies to personalise your interaction with social media, such as Twitter,
Facebook, Tumblr and YouTube. Such cookies recognise users of those social
media sites when you view social media content on our website. They also allow
you to quickly share content across social media, through the use of simple
‘sharing’ buttons.
Our website also contains features that enable you to use your Facebook account
to sign in and create/maintain an account with us and to enable us to store
your content. This involves the use of cookies.
WHAT HAPPENS WHEN
YOU REFUSE, BLOCK OR DELETE COOKIES?
In order to use some parts of our website you will need to accept cookies. If
you choose to withhold consent to our use of cookies, or you subsequently block
or delete cookies, some aspects of our website may not work properly and you
may not be able to access all or part of our website.
CAN YOU BLOCK
COOKIES?
You can block the use of cookies altogether by activating the relevant settings
in your browser or by following the link below. For more information on cookie
management and blocking or deleting cookies for a wide variety of browsers,
visit All About Cookies.
10. THIRD PARTY LINKS AND SERVICES
10.1. The VITAL PROTEINS Services
may contain links to third party websites and services. Please remember that
when you use a link to go from the VITAL PROTEINS Services to another website
or you request a service from a third party, this privacy notice no longer
applies.
10.2.
Your browsing and interaction on any other website, or your dealings with any
other third party service provider, is subject to that website’s or third party
service provider’s own rules and policies.
10.3. We
do not monitor, control, or endorse the privacy practices of any 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.
11. TRANSFERS OUTSIDE THE EEA
11.1. We may transfer your
personal data outside the EEA to processors outside the EEA including in the
USA, in connection with our business or for legal reasons. We will ensure that
the transfer is lawful and that there are appropriate security arrangements.
11.2. If
the European Commission has decided that a country does not provide an adequate
level of protection in relation to data that is transferred there, we will
enter into an agreement ensuring appropriate and suitable safeguards with our
group member, processors or other transferee. This may be via binding corporate
rules or on standard terms adopted by the Information Commissioner and approved
by the European Commission.
12. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
12.1. We do not keep your personal
data for any specific period but will not keep it for longer than is necessary
for our purposes.
In
considering how long to keep it, we will take into account its relevance to our
business and our legal and regulatory obligations.
13. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
13.1. We are committed to keeping
the personal information you provide us secure and we will take reasonable
precautions to protect it from loss, misuse or alteration.
13.2. We
have implemented information security policies, rules and technical measures to
protect the personal information that we have under our control from:
•
unauthorised access;
•
improper use or disclosure;
•
unauthorised modification; and
•
unlawful destruction or accidental loss.
13.3 All
our employees and data processors (i.e. those who process your personal
information on our behalf, for the purposes listed above), who have access to,
and are associated with the processing of personal information, are obliged to
respect the confidentiality of the personal information of all users of the
VITAL PROTEINS Services.
14. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
14.1. You have
the following rights in relation to the personal information we hold about you:
• Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information
and, if so, provide you with a copy of that personal information (along with
certain other details). If you require additional copies, we may need to charge
a reasonable fee.
• Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete,
you’re entitled to have it rectified. If we’ve shared your personal information
with others, we’ll let them know about the rectification where possible. If you
ask us, where possible and lawful to do so, we’ll also tell you who we’ve
shared your personal information with so that you can contact them directly.
• Your right to erasure.
You can ask us to delete or remove your personal information in some
circumstances such as where we no longer need it or you withdraw your consent
(where applicable). If we’ve shared your personal information with others,
we’ll let them know about the erasure where possible. If you ask us, where
possible and lawful to do so, we’ll also tell you who we’ve shared your
personal information with so that you can contact them directly.
• Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal
information in certain circumstances such as where you contest the accuracy of
that personal information or object to us processing it. It won’t stop us from
storing your personal information though. We’ll tell you before we lift any
restriction. If we’ve shared your personal information with others, we’ll let
them know about the restriction where possible. If you ask us, where possible
and lawful to do so, we’ll also tell you who we’ve shared your personal
information with so that you can contact them directly.
• Your right to data portability.
With effect from 25 May 2018, you have the right, in certain circumstances, to
obtain personal information you’ve provided us with (in a structured, commonly
used and machine readable format) and to reuse it elsewhere or ask us to
transfer this to a third party of your choice.
• Your right to object.
You can ask us to
stop processing your personal information, and we will do so, if we’re:
relying on our own or someone else’s legitimate interests to process your
personal information except if we can demonstrate compelling legal grounds for
the processing;
• processing your personal information for direct marketing; or
• processing your personal information for research unless such processing is
necessary for the performance of a task carried out in the public interest.
• Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic
processing, including profiling, and it produces a legal effect or similarly
significantly affects you unless such profiling in necessary for entering into,
or the performance of, a contract between you and us.
• Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for
processing your personal information for certain uses, you have the right to
withdraw that consent at any time for those uses.
• Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the
way we’ve handled your personal information, you can report it to the UK
Information Commissioner’s Office (ICO). You can find details about how to do
this on the ICO website at https://ico.org.uk/concerns/ or by calling their
helpline on 0303 123 1113.
15. CHANGE TO THIS PRIVACY NOTICE.
15.1. We may make changes to this privacy notice
from time to time
15.2. To ensure that you are always aware of how we use your personal
information we will update this privacy notice from time to time to reflect any
changes to our use of your personal information. We may also make changes as
required to comply with changes in applicable law or regulatory requirements.
We may notify you by email of any significant changes. However, we encourage
you to review this privacy notice periodically to be informed of how we use
your personal information.