Nội dung text Protein Holdings Privacy and cookies policy (GDPR).pdf
Privacy and cookies policy Updated 24th May 2018 1. Introduction • 1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data. • 1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this 2. How we use your personal data • 2.1 In this Section 2 we have set out: • (a) the general categories of personal data that we may process; • (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; • (c) the purposes for which we may process personal data; and • (d) the legal bases of the processing. • 2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. • 2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. • 2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. • 2.5 We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent. • 2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/ or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our Protein Holdings Ltd. 31 New Inn Yard, London, EC2A 3EY, UK - T +44 20 7247 3999 Protein is a registered trademark of Protein Holdings Ltd.
interest in the proper administration of our website and business. • 2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. • 2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. • 2.9 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. • 2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. • 2.11 Please do not supply any other person's personal data to us, unless we prompt you to do so. 3. Providing your personal data to others • 3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy. • 3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes. • 3.3 Financial transactions relating to our website and services are handled by our payment services providers, Xero. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://xero.com. • 3.4 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 4. International transfers of your personal data • 4.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). Protein Holdings Ltd. 31 New Inn Yard, London, EC2A 3EY, UK - T +44 20 7247 3999 Protein is a registered trademark of Protein Holdings Ltd.
• 4.2 We and our other group companies have offices and facilities in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. • 4.3 The hosting facilities for our website are situated in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. 5. Retaining and deleting personal data • 5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. • 5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. • 5.3 We will retain and delete your personal data as follows: (a) Personal data will be retained for 1 year, at the end of which period it will be deleted from our systems. • 5.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 6. Security of personal data • 6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. • 6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. • 6.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data. • 6.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology. • 6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. • 6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website). 7. Amendments • 7.1 We may update this policy from time to time by publishing a new version on our website. • 7.2 You should check this page occasionally to ensure you are happy with any changes to this policy. Protein Holdings Ltd. 31 New Inn Yard, London, EC2A 3EY, UK - T +44 20 7247 3999 Protein is a registered trademark of Protein Holdings Ltd.