Sequence Nutrition Limited understands that our customers value their personal privacy and wish to ensure that any company who provides a service to them will also value their privacy. We therefore guarantee that we will NOT sell or pass your data to any third party outside of Sequence Nutrition Limited, in the normal course of business. We do not share your personal data with any third parties, except to the extent it is required to share with our data processors in order to provide our services, in order to comply with legal obligations or to protect the rights and safety of Vitl and its customers. We take all steps reasonably necessary to ensure that your data is treated securely, with adequate protections when engaging processors on our behalf. As part of our customer charter we will process your personal data fairly and lawfully. If you have any questions about the below, please contact us: firstname.lastname@example.org.
INFORMATION THAT WE COLLECT ON OUR SITE
We collect information about you when you:
- visit our Site;
- register on or buy products on our Site;
- send a blood sample to our (or our partners') laboratories;
- send a DNA sample to our (or our partners') laboratories;
- take part in our promotions, competitions, customer surveys and questionnaires; or
- contact us via email, phone, social media or letter;
To enable us to process your order we will ask you to provide personal details including, but not limited to:
- Email address
- Delivery address
- Payment details
- IP address
Please note that we require certain types of information so that we can provide services to you. If you do not provide us with such information, or if you ask us to delete your information or account, we will no longer be able to provide our services to you.
No Credit Card numbers are held on our Site or on the associated back-office systems used by Sequence Nutrition Limited to process your orders. For future reference and to help us communicate with you, the last 4 digits only of your Credit Card number are kept by us.
For any repeat orders of Products made by you via our Site or if you opt in to have your details stored for future payments, our Payment Processing Agency securely holds your Credit Card details and provides us with a unique token that represents that particular card; this token is only valid for payment to us.
INFORMATION THAT WE COLLECT THROUGH OUR SERVICES
We will receive personal information about you from our business partners, suppliers and third parties that we may introduce you to (including doctors, laboratories and nutritionists), as part of our services. Such personal information will have been provided to us for the purpose of performing any contract we enter into with you (for example, providing you with the results of the test that you have chosen).
The types of personal information that we receive as a result of our services include the following special categories of personal data:
- Your race or ethnic origin
- Your physical or mental health or condition; and
- Biometric data (meaning data relating to your physical, physiological or behaviour)
We must obtain your explicit consent in order to process these special categories of personal data. We obtain your consent by you signing up to the service and accepting the Terms & Conditions. If you choose to withdraw your consent in accordance with the CUSTOMER CHOICE section below, we will be unable to provide our services to you.
We retain personal information for as long as you use the services we provide and then as required to comply with applicable laws.
INFORMATION THAT WE COLLECT FROM OTHER SOURCES
We will receive personal information about you from our business partners, suppliers and subcontractors. Such personal information will have been provided to us for the purpose of performing any contract we enter into with you.
We will receive information about you from advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
We will receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Site. We work closely with third parties (including, for example, advertising networks, analytics and search information providers) and may receive information about you from them.
The personal information that we collect from you might be transferred to, and stored in a location outside of the EEA. The personal information might also be processed by staff operating outside the EEA working for us, other members of our group or third party data processors. Such staff may be engaged in, among other things, the provision of our services to you, the processing of transactions and/or the provision of support services. By providing us with your personal information you acknowledge any such transfer, storage and processing.
HOW WE USE YOUR DATA
Our primary purpose in using your data is to provide you with your order. We may analyse your data to enable us to provide a better service to you.
We will keep all your personal information provided by you confidential, except that we may use personal information for any of the following purposes:
- administration, general correspondence, support and processing (including personalising the Site for your use);
- contacting you to register your use of the Site, to advise you of any special offers, to notify you of new features or to resolve any queries you or we may have regarding us or the Site or its use;
- developing and improving our products and services;
- contacting you to notify you of other services or Products that might be of interest to you;
- responding to any requests or queries from you;
- subscribing you to our newsletters or email alerts or online surveys;
- information collected via tracking technologies, as set out in the Tracking Technologies section below; and
- responding to any requests from the police and local government law enforcements agencies.
You may receive email content from us targeted to you if you opted in to receive these requests. Examples include:
- personalised content
- special offers
- information about other Vitl products
- Vitl market research
- account activity
You may opt out of marketing communications at any time by logging into your account.
We may share your personal data with any member of our group, which means Sequence Nutrition Limited, as the ultimate holding company, and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your personal data with selected third parties, including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in the normal course of business, and with trustworthy analytics and search engine providers that assist us in the improvement and optimisation of our services.
We may also disclose or share your personal data if we are under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements; or to protect the rights, property, or safety of Sequence Nutrition Limited. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
IP ADDRESSES AND COOKIES
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. This information is then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.
There are two types of cookies that can be used:
Persistent cookies - these cookies remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies - these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
COOKIES USED ON THE SITE
A list of all the cookies that may be used on the Site by category is set out below.
STRICTLY NECESSARY COOKIES
These cookies enable services you have specifically asked for. For the types of cookies that are strictly necessary, no consent is required.
These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies services you have asked for, such as shopping baskets or e-billing, cannot be provided.
These cookies collect anonymous information on the pages visited. By using the Site, you agree that we can place these types of cookies on your device.
These cookies collect information about how visitors use the Site; for instance, which pages visitors go to most often, which pages they go to next and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All the information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Site works.
These cookies remember choices you make to improve your experience. By using the Site, you agree that we can place these types of cookies on your device.
These cookies allow the Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
TARGETING OR ADVERTISING COOKIES
These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Want to know more about cookies?
SOCIAL MEDIA FEATURES AND WIDGETS
We, together with our analytics partners, use technologies such as cookies, beacons, tags, and scripts to enable a service to recognise your device so that you don't have to provide the same information several times during one task, to recognise that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how many people are using services.
We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our Site. Our third party partners may use technologies such as cookies to gather information about your activities within the Products to deliver such advertising to you, such as retargeting ads. We currently do not respond to do-not-track signals. For more information about interest-based ads, including how to opt-out of having your web-browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.
We use third party trackers to let us know when users have visited the Products by "clicking-through" our sponsored advertising or content hosted on third party platforms.
The Products use Google Analytics code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more information on how Google Analytics processes this information, visit www.google.com/analytics.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the Products, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.
As true of most websites, we gather certain information and automatically store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
YOUR CONSENT TO PROCESSING DATA
By Law, we are required to obtain your consent to processing your data. We will assume that you have given your consent to the uses outlined above if you provide us with any data via our websites or via replies to advertisements.
Where we process or transfer your data outside of what is outlined in "How we use your data" we will ask you to provide your specific consent.
HOW TO PROTECT YOUR DATA
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). If you have any questions regarding security you can contact us at email@example.com
Although Vitl is committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access and destruction and takes all reasonable precautions to safeguard the confidentiality of personal information, the transmission of data over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to our Site and that any such transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
You may contact us by sending an email to firstname.lastname@example.org to request the following:
- Request a data update
- Request a copy of your information
- Request that your account or any of your data be deleted permanently
We will adhere to updating, providing information or deleting your account within 30 days of request.
ICO Registration: ZA293612
Date: 24th May 2018
Version number: 3.0
Sequence Nutrition Ltd is registered under the The Health Insurance Portability and Accountability Act of 1996 (HIPAA). The Privacy Rule protects all "individually identifiable health information" held or transmitted by a covered entity or its business associate, in any form or media, whether electronic, paper, or oral. The Privacy Rule calls this information "protected health information" (PHI). The labs that Vitl use are also HIPAA compliant.