Welcome to the EMMAC Life Sciences Group’s Privacy Notice (“Notice”).
We are committed to protecting your privacy. This Notice details how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from under applicable law.
In this Notice “we“, “us” and “our” refers to all the companies of the EMMAC Life Sciences Group (“Group”). As this Notice applies globally, there may be differences in how we collect, use or disclose your Personal Information from country to country, in which case we will inform you about any specific processing activities that take place in your country.
EMMAC Life Sciences Limited, the parent company of the Group, has its registered office c/o Hill Dickinson LLP, The Broadgate Tower, 20 Primrose Street, London EC2A 2EW, (United Kingdom). Any company in our Group that provides you with goods, services or with whom you are in contact may use your Personal Information as described in this Notice.
For more information about us, our local companies, our brands and our presence in your jurisdiction, please visit uk.emmac.com.
By “Personal Information” (in some countries referred to as “personal data” or “personally identifiable information”) we mean any information relating to an identified or identifiable individual. This is broader than just information of a personal or private nature, and also includes information such as your name, date of birth, and e-mail address. Please see Section 2 below for what Personal Information is obtained from you.
By “Sensitive Personal Information” (in some countries referred to as “special categories of data”) we mean any Personal Information for example relating to an individual’s racial or ethnic origin or data concerning health. It also includes any other information deemed sensitive under applicable data protection laws.
- SCOPE OF OUR PRIVACY NOTICE
Our Notice applies to all Personal Information we collect, use, share or otherwise process through our business activities, both online and offline, (which we will refer to as “services” throughout this Notice), including:
– our websites (“Sites”);
– our official social media pages;
– our e-mails;
– our apps;
– our online and offline campaigns; and
– your conversations or correspondence with our representatives.
You should be aware of the fact that our Sites may contain hyperlinks to third party websites or apps, which are not controlled by us and which are not covered by this Notice. We have no responsibility or liability for the content and activities of these third party websites or apps nor are we responsible for the policies and practices of third party organisations that are not operating on our behalf. This includes: any third party website to which we link and the inclusion of a link does not imply endorsement of the linked website or service by us or by our affiliates or social media platform.
As these third parties may collect your Personal Information, you should consult their privacy policies to learn more about their use of your Personal Information.
- HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?
We collect your Personal Information as part of our business operations, to provide Services, to respond to requests and offer customer support, to fulfil legal and contractual obligations, and to develop our products. You provide some of this data directly, such as when you purchase a product, contact customer support, or register on our mailing list. We also collect information through your interaction with our Sites, for example using embedded product technologies and cookies. We may also obtain data from third parties.
Personal Information obtained from you directly
Firstly, we may obtain your Personal Information from you directly, e.g. when you sign up for our newsletters, register on our Sites, buy a product from us, fill out a survey, make a comment or enquiry, post something on our social media pages, create an account or subscribe to direct marketing.
Personal Information collected this way may include:
– Postal and Billing Address;
– E-mail address;
– IP address;
– User name;
– Telephone number
– Date of birth;
– Product purchase and usage information;
– Household information;
– Information, feedback or content you provide regarding your marketing preferences;
– User-generated content, posts and other content you submit to our Sites;
– Your views or opinions; or/ and
– Any other Personal Information you voluntarily provide us with directly.
From time to time, we may engage in analysis or research. In such circumstances, we may invite you to voluntarily share information with us.
Personal Information collected automatically
Personal Information collected this way may include:
– Information about your (mobile) device or your type of browser;
– Information about the way you use our Sites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.;
– Whether you have opened e-mails sent by us to you;
– The websites you have visited before arriving at one of our Sites;
– Your IP address;
– Geographical information (usually inferred by IP address)
– Your online activity;
– Your user name, profile picture, gender, networks, views and opinions and any other information you choose to share when using third party sites (such as when you use the “Like” functionality on Facebook);
– a hardware identification number that uniquely identifies each device on a network;
– Information you choose to share by using social media tools incorporated in our Sites or using your social media log-in details to access certain EMMAC product Sites or applications; and
– Information you share with us about your location. Where we are required to do so by local law, we will only use that information where you have agreed that we can.
Personal Information obtained from other sources
Lastly, we may also collect Personal Information about you from other sources. These other sources may include:
– Our trusted business partners
– Our suppliers;
– Social media sites;
– Consumer research organisations;
– Marketing agencies;
– Database providers;
– Credit reference agencies; and
– Other members of our Group.
Personal Information collected this way may include your purchase behaviour, publicly observed data or Personal Information from activities such as blogs, videos, internet postings and user generated content.
We take reasonable steps to confirm that information we receive from these third parties has been lawfully collected. We may also merge information about you that we receive from a number of sources, including directly collected from you and that collected from third parties.
Additionally we may receive information about you from another individual for example, where a friend posts content and tags or includes you. If you choose to share information about other individuals with us, you are responsible for ensuring that you have their permission to do so.
- THE PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL INFORMATION
We may use your Personal Information in the following circumstances:
– To fulfil our obligations with regards to your contract with us, (for example as a result of you making a purchase), which may include communicating with you with respect to your purchase, processing payments, delivering your orders, and to provide customer service. In many cases providing your Personal Information to us is necessary for the performance of your contract with us; if you do not wish to provide your Personal Information to us, we may not be able to provide you with the products and Services you have requested from us.
– Allowing you to participate in promotions, contests, surveys and polls;
– Allowing you to share information and ideas on our social media pages, forums, blogs and other communication channels, to participate in social sharing and to send messages to a friend through our Sites or the websites of our trusted business partners;
– To better understand your behaviours in order to provide you with more relevant information, developing and evaluating new products and improving our existing products and Services, conducting market research to inform, identifying user trends and product and development;
To examine the degree of effectiveness of our marketing campaigns and degree of satisfaction of our customers;
– Telling you about our products and Services, and sending you promotional materials (such as announcements relating to new products, promotions, savings programs, joint promotions and other programs) relating to our brands and those of our carefully selected trusted business partners, (subject to your consent to such marketing where required by applicable law);
– Managing our Sites, and their responsiveness to your previous activities;
– Responding to your enquiries;
– Dealing with any product adverse events you report to us;
– Administering general record keeping;
– Meeting legal and regulatory requirements;
– To conduct research to improve our products, Sites and/ or Services;
– To run our business; for example, to perform accounting, auditing, and billing activities.
– With your consent
– In our legitimate and lawful interests (in each case provided such interests are not overridden by your rights) unless stated otherwise.
– With your explicit consent in limited circumstances.
– Other business purposes that depend on use of your personal information include crime or fraud monitoring and prevention, and protecting our legal rights.
– where it is required to satisfy any legal or regulatory obligations that we are subject to.
We may create anonymous data records from Personal Information by excluding all information (such as your name) that makes the data personally identifiable to you.
- TO WHOM WE MAY DISCLOSE YOUR PERSONAL INFORMATION
Your Personal Information may be shared between the different companies and brands of our Group, for the purposes set out in this Notice. As we have stated above, this Notice applies to all these companies’ and brands’ use of your Personal Information.
We may share your Personal Information with our chosen email provider, Mailchimp. Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a US company that stores Personal Information in the US. The Rocket Science Group LLC is registered under the EU-US Privacy Shield framework – see Section 11 below.
The Mailchimp services enable us to, among other things, send and manage email campaigns, serve advertisements and view real-time data analytics. You can find out more about how Mailchimp collects and stores your information at https://mailchimp.com/legal/privacy/
We may share your Personal Information with other trusted third party service providers and suppliers who work on our behalf, such as marketing agencies, market research companies, e-commerce fulfilment partners, software, data hosting and other IT service providers, merchants selling EMMAC products, call centres and payment processors. These third party service providers are required to use your Personal Information only to provide the services requested by us or otherwise in accordance with our instructions and in accordance with contracts which include provisions to protect your Personal Information and limit its use.
We may also share your Personal Information with our business partners, advertisers (where we are permitted to do so) and data exchanges, so that we can offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to deliver customised content and advertising to you.
Our Sites and/or applications may also allow you to log in using a social network or other third-party account. An example of a third-party login is “Log in with Facebook”. Logging into one of our Sites with your social network or other third-party account may allow us to gather information that you give us permission to access from that social network or third party. The login feature may also transfer information to the social network or third party, such as your username and password, to authenticate you. You should refer to that third party’s privacy notice for how your Personal Information is processed by them.
If the Group is acquired or another company acquires a Group company, business, or our assets, we may disclose your Personal Information as part of that actual or contemplated transaction, and that company may acquire all or part of the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Notice. In the unlikely event of an insolvency, bankruptcy or receivership, your Personal Information may also be transferred as a business asset, subject to applicable law.
We may disclose your Personal Information only where lawful to do so.
- HOW WE PROTECT YOUR PERSONAL INFORMATION
We value the trust you place in us.
We have implemented appropriate technical and organisational measures to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing. We take various steps to minimise the volume of Personal Information we processed.
The Personal Information you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.
- YOUR CHOICES REGARDING DIRECT MARKETING
We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our products and Services which we believe are useful for you, if you have consented (opted-in) to receive such messages (where such opt-in is required under applicable law).
If you do not wish to receive such communications anymore, you will always have the opportunity to “opt out” by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see our contact information at “how to contact us” below).
- YOUR RIGHTS
Depending on your location, you may have various rights in relation to your Personal Information. In particular, you may have the right to:
Request a copy of Personal Information we hold about you;
Ask that we restrict the way in which we use your Personal Information;
Ask that we update the Personal Information we hold about you, or correct any Personal Information that you think is incorrect or incomplete;
Ask that we delete Personal Information that we hold about you (the “right to be forgotten”);
Withdraw consent at any time to our processing of your Personal Information (to the extent such processing is based on consent);
Object to our processing of your Personal Information (including for direct marketing purposes); or
Request your Personal Information be transferred to you or another data controller (the “data portability” right).
In order to enact any of your rights, please contact us at the contact address below. Please note that, in the event you request that we change or delete your Personal Information, we may still need to retain certain information as is required by applicable law.
If you are unhappy with the way we have handled your Personal Information or have any privacy query, you can contact us in accordance with Section 12 below (How To Contact Us). Additionally, you have a right to complain to your local data protection regulator. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance – details are provided in Section 12 below.
- HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We will only retain your Personal Information as long as is reasonably required for the purposes as set out in this Notice or otherwise to comply with legal or regulatory requirements applicable to us. When your personal information is removed from our systems, it is deleted or destroyed securely.
When your Personal Information is processed:
– For the performance of your contract with us, we retain your Personal Information for a period of 6 years following completion of a contractual order;
– For meeting, legal and regulatory requirements, we retain your Personal Information as it is set out by the applicable law; and
– In all other cases, we process your Personal Information, depending on the type, for up to 2 years from the date of our last interaction with you.
- CHILDREN AND AUTOMATED DECSION MAKING
Our Sites are not directed towards children and we request that children below the age of 18 do not provide Personal Information through our Sites.
We do not use your Personal Information to make automated decisions about you.
- TRANSFERS TO OTHER COUNTRIES
Your Personal Information may be transferred to and processed in other countries where laws governing the processing of Personal Information may be less stringent than the laws in your country (including jurisdictions outside the European Economic Area).
In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your Personal Information. Depending on the location of the EMMAC entity exporting the relevant Personal Information, this adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request.
To the extent required and valid under your local law, you consent will be obtained for your Personal Information being transferred and processed this way.
- HOW TO CONTACT US
We welcome your feedback. If you have any comments, questions or complaints regarding this Notice or our processing of your Personal Information, or would like to exercise any of the rights set out at “your rights”, you can contact us by sending an e-mail to email@example.com or contact us at firstname.lastname@example.org
You may also write to us at:
Emmac Life Sciences Limited
Data Privacy Queries
c/o Hill Dickinson LLP
The Broadgate Tower
20 Primrose Street
London EC2A 2EW
- CHANGES TO THIS PRIVACY NOTICE
This Notice was last modified in June 2020. We may occasionally modify or update it from time to time and you should ensure that you regularly review it from time to time. When we make changes to this Notice, we will update the revision date above. Where those changes are material, we will take steps to let you know. The new modified or amended Notice will apply from that revision date. Please always verify whether you have consulted the latest version of the Notice. We will treat your continued use of the Site and our Services as your acceptance of this Notice in its then published format, unless your explicit consent is required by applicable data protection laws.
The controller is:
Emmac Life Sciences Limited (Registered in England with registered number 11253633)
Emmac Life Sciences Limited
Data Privacy Queries
c/o Hill Dickinson LLP
The Broadgate Tower
20 Primrose Street
London EC2A 2EW
A list of supervisory authorities may be found here.