Privacy & Cookies Policy
Nutri Advanced Pus Ltd
1. Who are we?
In the context of our activities (the sale of food supplements via a network of distributors and other sales channels, as well as the follow-up and the provision of aftersales services) we collect, hold, disclose and/or otherwise process personal data. Pursuant to the applicable data protection legislation, we qualify as the controller in this respect.
We value your right to privacy and strive to protect your personal data in accordance with applicable data protection legislation and more specifically with the General Data Protection Regulation (“GDPR”) and applicable national data protection legislation.
Note: This does not mean that we need your ‘consent’ to the processing of your personal data. We do not process your personal data on the basis of your consent, unless specifically indicated (e.g. for sending our electronic newsletter).
3. Whose personal data do we collect?
In the context of our services (as described above), we may process personal data of contact persons at our suppliers, distributors, clients or other commercial partners, of doctors or other professionals, of visitors or participants to a congress or another event (including speakers), of consumers who buy or use our products, and of visitors of our website(s).
4. How do we collect personal data?
We may collect information about you in various ways, e.g.:
- directly from you when you provide us with your personal data (as a visitor, or as a participant or speaker during a congress, meeting or another event organised by us or by a third party);
- directly from you in the context of contractual negotiations or the conclusion of an agreement (e.g. a purchase from our web shop);
- directly from you when you register on our website(s), when you navigate our website(s), when you complete a contact form on our website(s) or when you register for our electronic newsletter;
- directly from you when you participate in a contest organised by us;
- directly from you (e.g. doctors) during a visit or another contact moment by one of our sales agents/representatives;
- via our distributors or professional clients, when you provide your personal data to them in the context of a purchase or a request for information; or
- via third parties and official sources of publicly available information.
5. What personal data do we collect and for what purpose?
6. With whom do we share your personal data
- With our service providers (‘processors’) and commercial partners:
In the context of our activities as described above, we may share your personal data with third parties, in particular with service providers (such as IT/cloud service providers or PR/marketing service providers who organise mailing campaigns for us) that act as our ‘processors’, and with commercial partners with whom we co-organise events or contests or otherwise develop joint initiatives.
- Within our group of undertakings and with our network of agents and distributors:
We may also share your personal data within our group of undertakings (as our affiliates often assist us with operational management or IT, or where required to report certain information to our parent companies or for global management and business strategy purposes) and with our distributors, agents, or commercial partners (so that they can contact you to follow up on your question or concern or to provide information requested by you).
- With consultants and advisors:
We also share personal data, where necessary, with consultants, (legal or other) advisors who assist us in the performance of our commercial activities or to advise us, and with relevant other third parties, e.g. in the event of (impending or pending) litigation or in the event of a contemplated merger, divestment or sale of (part of) our business, assets or shares in our company, in which case certain data needs to be made available to advisors and to potential buyers/investors in a (secured) data room for due diligence purposes.
- With government authorities:
Further, we may share your personal data with the government, police authorities or the judiciary in case we have a legal obligation to do so.
We will share your personal data with these third parties only if this is necessary for the above mentioned purposes.
We will implement appropriate safeguards when transferring your personal data to third parties. If necessary, we will for example conclude a processing agreement specifying the limitations to the use of your personal data and the obligations with respect to the security of your personal data.
Some of the aforementioned parties to whom we may disclose your personal data as referred to above may be located in countries outside the European Economic Area, which may offer a lower level of data protection. For example, the transfer of personal data to our non-EEA affiliates (e.g. in Australia) and in particular to our parent companies located in the United States. In such case, we will ensure that adequate measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation. More specifically, we have implemented the approved EU standard Contractual Clauses for the transfer of personal data (“controller to controller”) for intra-group transfers of personal data. A copy hereof is available upon request.
7. How long do we process your personal data?
Your personal data will not be processed for longer than is necessary in relation to the purposes listed above. Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed in a file.
More specifically, the following processing limitations apply: For direct marketing purposes we keep personal data as long as we plan to continue sending relevant information to the contacts on our mailing lists, unless (i) we note that their (e-mail) address is out of use, or (ii) we are notified that he/she wants to opt-out of receiving any further mailings.
Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings (e.g. in case of a dispute), we will process the personal data for longer periods.
More information on the specific personal data retention periods we apply is available upon request.
8. How do we protect your personal data?
We will implement the necessary administrative, technical and organisational measures for ensuring a level of security appropriate to the specific risks that we have identified.
We protect your personal data against destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
Further, we seek to ensure that we keep your personal data accurate and up to date. In view thereof, we kindly request you to inform us of any changes to your personal data (such as a change in your contact details).
More information on our protection measures is available upon simple request.
9. What are your rights and how can you exercise them?
You have (under certain conditions) the right to:
- information about and access to your personal data;
- rectify your personal data;
- erasure of your personal data (‘right to be forgotten’);
- restriction of processing of your personal data;
- object to the processing of your personal data;
- receive your personal data in a structured, commonly used and machine readable format and to (have) transmit(ted) your personal data to another organisation.
To read more about these rights, and circumstances under which you can use these rights, in particular your right to object (this is your ‘opt-out’ right for our electronic newsletter and for call-back campaigns (by subscribing to the ‘do not call’ list)), see the Annex to this document. In principle you may exercise these rights free of charge. Only where requests are manifestly unfounded or excessive we may charge a reasonable fee.
We aim to respond as quickly as possible, and in any case within one month, to your requests or questions. Please note that certain requests may be refused in order to protect our own business secrets or the privacy interests of others.
Finally, if you wish so, you have the right to lodge a complaint with your local Data Protection Authority in relation to the processing of your personal data by us:
- In Belgium: the Data Protection Authority (dataprotectionauthority.be);
- In the Netherlands: the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl)
- In Italy: the Garante Privacy (garanteprivacy.it)
- In Ireland: the Data Protection Commisssion ( dataprotection.ie)
- For other EU Member States: see https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Annex – More information about your rights as a data subject
|Right to information and right to access your personal data||You may at any time request more information on our processing activities and the personal data that we are keeping from you.|
|Right to rectification of inaccurate or incomplete personal data of||You have the right to require us to, without undue delay, rectify or complete any of your personal data that is inaccurate or incomplete.|
|Right to deletion of your personal data (‘right to be forgotten’)||
You may request us to delete (part of) your personal data in the following situations:
- when the processing is no longer necessary for achieving the purposes for which they we collected or otherwise processed these; or
- when the processing was based on your consent and you have decided to withdraw that consent;
- when you have other reasonable grounds to object to the processing of your personal data;
- when we would unlawfully process your personal data;
- when your personal data have to be erased in compliance with a legal obligation directed to us.
We note that in some case, we may refuse to delete your personal data: (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation; or (iii) for the establishment, exercise or defence of legal claims.
Right to restriction of processing
You may request us to (temporarily) restrict the processing of your personal data in the following situations:
- when you have contested the accuracy of your personal data, for a period enabling us to verify this accuracy; or
- when the processing appears to be unlawful and you request us the restriction of use of your data instead of the deletion of this data; or
- when we no longer need the personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims; or- pending verification whether our legitimate grounds override yours in the framework of an objection.
Right to object to the processing of your personal data (free of charge)
You may under certain circumstances object to the processing of your personal data, when such processing is based on our “legitimate interests”. If we agree, we will no longer process your personal data, unless we have compelling legitimate grounds to do so, or because such a processing is necessary.
Where we process your personal data for direct marketing purposes (in particular for sending our electronic newsletter or personalised advertisement via regular mail), you may at any time object to the processing thereof or withdraw your consent thereto. You also have the right not to be subject to profiling for direct marketing purposes.
|Right to data portability||
In some cases, you have the right to receive all your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. This right applies:
- in case the processing is carried out by automated means.
Cookies Policy (Version 29.09.2022)
11. What is the purpose of this policy?
This Cookies Policy serves to inform you thereof, so that you can easily manage your cookie-settings.
12. What are cookies and why are they used?
Cookies are small pieces of data that are stored on your computer or mobile device via your browser.
Some of the cookies that we use on our Websites are essential to make our Websites work, others serve to provide you a better, faster and safer user experience.
Cookies are often classified in the following categories:
- “session cookies”: cookies that are automatically erased once the user exits the web browser window;
- “persistent cookies”: cookies that are placed on a user’s hard drive and stay there for a certain period of time (cookies can expire after several minutes, days or years);
- “first-party cookies”: cookies that are developed and placed by the website operator itself; and
- “third parties cookies”: cookies that are placed by a third-party, not the website operator itself.
You will find more information on the specific cookies that we use on our Websites in point 4 below. Under point 5 you will learn how to manage these cookies and, if desired, how to delete them.
13. Which cookies do we use?
Hereinafter you can find a list of the cookies that we are using on our Websites.
14. How can you manage / delete these cookies?
All major internet browsers offer the option to manage the cookies that were installed on your computer or mobile device.
In case you do not want that these Websites place cookies on your computer or mobile device, you may limit or delete this easily by adjusting your browser or mobile settings. In addition, you can set you browser or mobile settings in such a way that you get a notification every time you receive a cookie on your computer or mobile device, so that you can decide whether you wish to accept this cookie or not.
- Click the wrench icon on the browser toolbar
- Select Settings
- Click ‘Show advanced settings’
- In the “Privacy” section, click the ‘Content settings’ button
- To enable cookies in the “Cookies” section, pick ‘Allow local data to be set’, this will enable both first-party and third-party cookies. To allow only first-party cookies pick ‘Block all third-party cookies without exception’
- To disable cookies, in the “Cookies” section, pick ‘Block sites from setting any data’
Note there are various levels of cookie enablement and disablement in Chrome. For more information on other cookie settings offered in Chrome, refer to the following page from Google: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Microsoft Internet Explorer 6.0, 7.0, 8.0
- Click on 'Tools' at the top of your browser window and select 'Internet Options'
- In the options window navigate to the 'Privacy' tab
- To enable cookies: Set the slider to ‘Medium’ or below
Note there are various levels of cookie enablement and disablement in Explorer. For more information on other cookie settings offered in Internet Explorer, refer to the following page from Microsoft: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
- Click on 'Tools' at the browser menu and select ‘Options’
- Select the Privacy panel
- To enable cookies: Check ‘Accept cookies for sites’
- To disable cookies: Uncheck ‘Accept cookies for sites’
Note there are various levels of cookie enablement and disablement in Firefox. For more information, refer to the following page from Mozilla: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
- Click on 'Setting’ at the browser menu and select 'Settings'
- Select ‘Quick Preferences’
- To enable cookies: check “Enable Cookies”
- To disable cookies: uncheck “Enable Cookies”
Note there are various levels of cookie enablement and disablement in Opera. For more information on other cookie settings offered in Opera, refer to the following page from Opera Software: http://www.opera.com/browser/tutorials/security/privacy/
Safari on OSX
- Click on 'Safari' at the menu bar and select the 'Preferences' option
- Click on 'Security'
- To enable cookies: In the 'Accept cookies' section select 'Only from site you navigate to'
- To disable cookies: In the ‘Accept cookies’ section select ‘Never’
Note there are various levels of cookie enablement and disablement in Safari. For more information on other cookie settings offered in Safari, refer to the following page from Apple: http://docs.info.apple.com/article.html?path=Safari/3.0/en/9277.html
All other browsers
Please look for a “help” function in the browser or contact the browser provider.
15. Processing of your personal data via cookies and similar technologies
- the right of information about and access to your personal data;
- the right to rectify or erasure of your personal data (‘right to be forgotten’);
- the right to restriction of processing of your personal data;
- the right to object to the processing; and
- the right to data portability.
Finally, if you wish so, you have the right to lodge a complaint with your local Data Protection Authority in relation to the processing of your personal data by us.
16. Changes to this Cookies Policy
From time to time, we may need to change this Cookies Policy, for example in case of use of new functionalities on our Websites. We therefore encourage you to regularly review this Cookies Policy. Important amendments will be announced on our Websites. This version of the Cookies Policy was last modified on 29.9.2022.
If you have any questions, comments or complaints in relation to this Cookies Policy, please feel free to contact us by regular mail at the attention of the Data Protection Office at Edward Vlietinckstraat 20, 8400 Oostende, Belgium or via [email protected].