PRIVACY POLICY
- GENERAL
1.1 Personal integrity and correct processing of personal data is important to us at GetVitamine Scandinavia AB, reg.no. 559314-8736 (“VitaMine”, “we”, “us” or “our”). The purpose of this privacy policy ("Privacy Policy") is to inform you about our processing of your personal data and what rights you have as a data subject. VitaMine's processing of personal data is carried out in accordance with applicable legislation, which includes the Data Protection Regulation of the European Parliament and of the Council ("GDPR").
1.2 This Privacy Policy forms an integral part of our general terms and conditions. Terms defined in our general terms and conditions also applies to this Privacy Policy unless otherwise stated herein.
1.3 This Privacy Policy is applicable to the personal data we may process about you as a User in connection with the use of our Service and Website. VitaMine is the personal data controller for the personal data you provide us with through your use of the Service or the Website.
1.4 Set forth below in this Privacy Policy is a description of how we process your personal data, and the table in Appendix A sets out the details hereof including the types of personal data as well as each processing activity conducted in relation thereto. If you would like to receive further information about the processing of your personal data, please contact us at legal@getvitamine.com
- PERSONAL DATA THAT WE PROCESS
2.1 Personal data refers to information that can be directly or indirectly associated with a living natural person. We process the following main categories of personal data (i) contact information, (ii) personal information, (iii) sensitive personal data, (iv) information about Product orders, (v) payment and user information, (vi) marketing preferences, (vii) user generated data, (viii) device information and (ix) contact with customer services and feedback.
2. We may process sensitive personal data / special categories of personal data about you when you use our Service in order to deliver customised Products to you. Such special categories of personal data constitute certain health data that you provide to us in connection with carrying out the health examination / consultation in the Service and ordering our Products. The processing is necessary for us to be able to analyse your responses, prepare and deliver our Products to you that you ordered through our Service. In order to carry out the consultation in our Service and thus provide us with certain health data, you will need to provide your explicit consent to us processing such data in accordance with what is stated in this Privacy Policy.
2.3 We may also process special categories of personal data other than health data if it is necessary to fulfil our obligations under applicable law (i.e., if we have a legal obligation to do so).
2.4 The personal data that VitaMine processes is provided either by you directly or indirectly via our Service or by you indirectly through any third party with whom we collaborate (if you actively make the choice in our Service to transfer data to us from such parties) and if necessary in order to register you as a user of our Service, we may also collect personal data from private and public registers, publicly available sources and from public authorities.
2.5 For further information about the categories and types of personal data processed by us, see the table in Appendix A.
- LEGAL BASIS AND PURPOSE OF THE PROCESSING
3.1 We process your personal data for various purposes. We will always ensure that we have a lawful basis for processing your personal data. The table in Appendix A, Section 2, further describes the details of the purpose for the respective processing activity of the personal data, including the legal basis for the processing in question.
3.2 We process personal data in accordance with this Privacy Policy (i) to fulfil our obligations pursuant to an agreement with you, (ii) to fulfil our legal obligations under applicable law, (iii) if we have a legitimate interest to process the personal data and/or (iv) if we have your consent to process your personal data. For specific processing activities, more than one lawful basis may be applicable.
3.3 If we intend to process your personal data for any specific purpose that requires your consent under the GDPR, or other applicable legislation, we will ask for your consent in advance. The consent will contain information about the specific processing activity. If you have provided your consent to a specific processing activity of your personal data, you can always withdraw such consent (see Section 7.2 below regarding your rights). In such case, we will no longer store or process your personal data for that specific purpose. However, the processing of your personal data for other purposes in accordance with this Privacy Policy may not be affected by such withdrawing of your consent for a specific purpose.
3.4 If we intend to process personal data in a way that is likely to lead to a high risk for data subjects' freedoms and rights, we will prior thereto carry out a data protection impact assessment in accordance with GDPR before we initiate such processing, through which we (i) systematically review the envisaged processing operation and its purpose, (ii) make an assessment regarding the necessity and proportionality of the processing operations in relation to the purposes, (iii) make an assessment of the risks of the data subject's rights and freedoms and (iv) ensure that measures taken meet the requirements according to the GDPR. We only use processes subject to a data protection impact assessment according to the GDPR that have been approved by us subject to such assessment as described herein. The use of such processes that have been subject to an data protection impact assessment are monitored and reassessed continuously by us in accordance with our established routines from time to time.
3.5 If we intend to process personal data for a specific purpose based on our legitimate interest, we prior thereto conduct a so-called assessment of balance of interests, whereby we evaluate, among other things, whether our legitimate interest is overridden by the fundamental rights and freedoms of the data subject in accordance with the GDPR. We only process personal data based on our legitimate interest if we make the assessment that our legitimate interest is not overridden by the relevant data subject's interests and rights according to the GDPR.
- SECURITY MEASURES; EXTERNAL PARTIES ETC.
4.1 Personal data is always treated confidentially and protected by appropriate security measures. VitaMine ensures that companies that process and/or manage personal data on our behalf uses a high level of security measures to protect your personal data. However, please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of the data sent to us in this way. Transmission of personal data over the internet is at your own risk. You are responsible for keeping all passwords you use to access our platforms secure and not disclosing your passwords to third parties.
4.2 We may disclose your personal data to external parties with whom we collaborate for the purpose of performing our Service, delivering our Products and/or conducting our business. However, we will always ensure that we enter into agreements with such parties to whom we provide your personal data in accordance with the GDPR. Categories of such external parties are: shipping companies, product packaging companies.
4.2.1 Suppliers and sub-suppliers regarding the Product
Description of the external parties: Suppliers and sub-suppliers are companies that only have the right to process the personal data they receive from us on our behalf (i.e. personal data processors). Examples of such suppliers and sub-suppliers are producers of dietary supplements and vitamins (i.e. the Products), suppliers of packaging and labelling of the Products, etc., software and data storage suppliers, e-mail suppliers, other IT suppliers and business consultants.
Purpose and legal basis: We need access to services and functionalities from other companies that we cannot provide ourselves in order to deliver our Service, Product and Website. We have a legitimate interest in being able to access these services and functionalities and we ensure that the processing it entails is necessary to fulfil the interest in question. In this case, our interest overrides the relevant data subject's right to not have its data processed. To the extent that sensitive personal data is included in the processing activity based on the stated purpose herein, this is based on your explicit consent thereto. However, Users have the right to withdraw their consent or object to processing activities, due to circumstances in each individual case, and more information about Users rights can be found in Section 7.
4.2.2 Payment service providers and other financial institutions
Description of the external parties: Payment service providers and financial institutions that provide services to the Users and VitaMine to carry out and administer electronic payments through a variety of payment methods, such as for example credit cards, bank-based payment methods (direct debit and bank transfer).
Purpose and legal basis: We share your information with payment service providers for administration of payments. The sharing of your data takes place in accordance with our Privacy Policy, but some payment service providers also collect and use your information independently as personal data controllers in accordance with their respective data protection information. This is, for example, the case for suppliers of electronic wallets. VitaMine may share your information with financial institutions when you execute transactions with your account in order to complete the transactions. The provision of personal data to payment service providers and financial institutions is made in order to carry out a transaction you initiated of a Product and to fulfil the agreement with you (you can find the terms of use of our Service [here].) To the extent sensitive personal data is included in the processing activity based on the relevant purpose herein, this is based on your explicit consent thereto. However, as a User you have the right to withdraw your consent or object to processing activities, due to circumstances in the individual case, and more information about User rights can be found in Section 7.
4.2.3 Logistics and transport companies
Description of the external parties: Logistics and transport companies
Purpose and legal basis: We share your data with logistics and transport companies to deliver the Products you ordered. Examples of information we share with such parties are contact and identification information as well as package tracking numbers. These parties process your data in accordance with their own data protection policy. The transfer of information to logistics and transport companies is carried out to fulfil the agreement between you and VitaMine.
4.2.4 Companies within the VitaMine group
Description of the external parties: companies within the VitaMine group
Purpose and legal basis: We need access to services and functions from other companies that we cannot provide ourselves in order to deliver our Service, Product and Website. We have a legitimate interest in being able to access these services and functions and we ensure that the processing it entails is necessary to fulfil the interest in question. In this case, our interest overrides the data subject's right to not have its data processed. To the extent that sensitive personal data is included in the processing with the stated purpose, this is based on your explicit consent thereto. However, Users have the right to withdraw their consent or object to processing activities, due to circumstances in the individual case, and more information about User rights can be found in Section 7.
4.2.5 Authorities
Description of the external parties: We may provide necessary information to authorities such as the Police, the Tax Agency and other authorities and courts.
Purpose and legal basis: Transfer of your personal data to authorities is made when we are required by law to do so, in some cases if you have requested this, if it is required to administer tax deductions, prevent crimes, etc. Depending on the authority and purpose, the legal basis is (i) obligation to comply with the law, (ii) to fulfil the contract with you or (iii) that we have a legitimate interest in protecting ourselves from crimes.
4.2.6 Professional advisors
Description of the external parties: We may provide necessary information to professional advisors (such as legal and financial advisors and other experts).
Purpose and legal basis: Transfer of your personal data to professional advisors is made when we have a need for legal or financial advice. Depending on the purpose, the legal basis is (i) legitimate interest to investigate our statutory obligations, (ii) legitimate interest to protect ourselves from crimes, (iii) legitimate interest to protect us in a dispute, or (vi) to fulfil a contract between you and VitaMine.
4.2.7 Potential purchaser of the business or assets
Description of the external parties: If VitaMine sells its business or assets, VitaMine may provide your personal data to a potential buyer of the business or assets. Personal data about VitaMine's customers may be shared if a significant part of VitaMine's assets is acquired by a third party.
Purpose and legal basis: VitaMine has a legitimate interest in being able to carry out transactions of our assets or business and we ensure that the processing it entails is necessary to fulfil the interest in question. In this case, our interest overrides the data subject's right to not have its data processed. To the extent that sensitive personal data is included in the processing activity with the stated purpose, this is based on your explicit consent thereto. However, Users have the right to withdraw their consent or object to processing activities, due to circumstances in the individual case, and more information about User rights can be found in Section 7.
4.2.8 Partners with whom we collaborate within the scope of the Service
Description of the external parties: Collaborative partners within the scope of the Service and offers and benefit programs provided via the Service / Website (e.g., conversational therapists, psychologists, health companies and similar collaborative partners).
Purpose and legal basis: If Users choose to take part in offers and benefits that VitaMine delivers within the framework of the Service, VitaMine shares the information required for you to be able to take part in the offer with our partners. What personal data is included in connection with such specific offer or benefit is specified for each such offer or benefit. The transfer of data is based on your consent (if sensitive personal data is included in the processing) and/or to fulfil an agreement between you and VitaMine.
4.2.9 Partners operating within health and care
Description of the external parties: External partners who are operative in the health and care section (e.g., psychologists, health and/or healthcare companies and similar companies or actors) who need to receive an anonymized report regarding the general state of health.
Purpose and legal basis: VitaMine may share anonymized reports generated by us based on your personal data obtained by you through your use of the Service. VitaMine has a legitimate interest in generating and sharing anonymized reports regarding the general state of health to external partners and we ensure that the processing it entails is necessary to fulfil the interest in question. In this case, our interest overrides the data subject's right to not have their data processed. However, Users have the right to object to processing activities, due to circumstances in the individual case, and more information about User rights can be found in Section 7.
- TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
5.1 In order to perform our Services and/or conduct our business, we may transfer and store personal data in countries outside the EU/EEA (“Third Countries”), in accordance with Appendix B hereto. Such transfer occurs when: (i) we transfer the data to external parties, in accordance with Section 4.2 (personal data processors), established in a Third Country, or (ii) data is stored on a cloud service, or a server based in a Third Country.
5.2 When VitaMine transfers personal data to Third Countries, we will take reasonable legal, technical and organisational measures to ensure that your personal data is adequately protected, at the same level as it would have been within the EU/EEA through the use of relevant safeguards. For the avoidance of doubt, such transfer referred to herein, if applicable, will only include the type of personal data relevant to the purpose of the processing.
5.3 Regardless of what is stated about the relevant protective measures taken, you as a User acknowledges and agrees that the transfer to and processing of personal data in a Third Country may entail a risk that the personal data cannot be protected at the same level as within the EU/EEA.
5.4 Further details regarding relevant safeguards when transferring personal data to a Third Country are set out in Appendix B and if you would like more information about the transfer of personal data to a Third Country, you can contact us at legal@getvitamine.com
- STORAGE AND DELETION OF PERSONAL DATA
6.1 Personal data will only be stored for a limited period of time and no longer than necessary in order for us to fulfil the purposes of the processing (see Appendix A, Section 2 therein), or for as long as we are required to store the information according to applicable legislation and relevant guidelines. This will depend on a number of factors, including for example (i) the laws and regulations that we are required to follow, (ii) whether we are in a legal or other type of dispute with each other or a third party, (iii) the type of information that we hold about you, (vi) whether we are asked by you or a regulatory authority to keep your personal data for a valid reason. If processing of your personal data is no longer necessary, it will be erased in accordance with our erasure procedure from time to time. We make the assessment in each case regarding if we are entitled to store your data, which you can find more information about in Appendix A, Section 2 therein.
6.2 Depending on the relevant purpose of the processing of your personal data, we may store the data in accordance with what is specified in the below list in this Section. In the event that VitaMine are processing your personal data based on the legal obligations described below, we cannot delete the personal data even if you were to request such action. Should we no longer be required to save your personal data due to a legal obligation, we will make an assessment whether we are in need of the data in order to safeguard our interest in any legal or other type of dispute.
(i) Personal data processed as a result of an agreement between you and VitaMine are stored during the term of the agreement and a maximum of ten (10) years thereafter due to statute of limitation.
(ii) Personal data we store as a result of applicable legislation such as anti-money laundering and accounting legislation are normally stored for five (5) respective seven (7) years.
(iii) Should VitaMine no longer have a legal obligation for the processing of the personal data, the data is stored as long as necessary in order to fulfil each applicable purpose of the processing (we normally erase or anonymize the personal data after thirty-six (36) months), more information hereto is set out in Appendix A, Section 2 therein.
6.3 If VitaMine is subject to liquidation or bankruptcy or if VitaMine’s customer database is transferred to a third party conducting similar activities as VitaMine, VitaMine shall thereafter erase your personal data, provided however that VitaMine is not required to store the information according to applicable legislation and relevant guidelines. If VitaMine is subject to a merger, acquisition, reorganisation or similar process, VitaMine will continue the processing of your personal data pursuant to this Privacy Policy unless otherwise is specifically announced to you in connection with such process.
6.4 You can unsubscribe from our newsletters or similar communications at any time. In such case, we will no longer store or process your personal data for that particular purpose, i.e. to provide newsletters. However, processing of your personal data for purposes other than to provide newsletters and similar communications, if applicable, in accordance with this Privacy Policy is not affected by your request to unsubscribe from our newsletters. More information about your rights as a registered person can be found in Section 7 below.
- YOUR RIGHTS AS A DATA SUBJECT
7.1 VitaMine is the controller for the processing of your personal data in accordance with this Privacy Policy, and as a data subject you have certain rights as regards your personal data. The rights are however not absolute, meaning that there are exceptions to some of the rights where we cannot proceed and fulfil your request.
7.2 As a data subject, you have the following rights:
(i) Right to withdraw your consent – meaning that you have the right to at any time withdraw your consent where VitaMine process your personal data based on your consent;
(ii) Right to access – meaning that you have the right to request a confirmation of our processing of your personal data, to receive information about the processing, access the personal data in question, and the right to obtain a copy of your personal data;
(iii) Right to rectification – meaning that you have the right to have any incorrect personal data about you as a data subject corrected by us;
(iv) Right to erasure – meaning that you have the right to have your personal data erased under certain circumstances. This right is limited, and we may be obligated to save your personal data in accordance with applicable law;
(v) Right to object – meaning that you have the right to object to VitaMine’s processing of your personal data under certain circumstances (for example you may object to processing of your personal data if we base such processing on our legitimate interest and you have the right at any time to object to VitaMine’s processing of your personal data for direct marketing purposes etc.);
(vi) Right to restricted processing – meaning that you have the right to have VitaMine restrict the processing of your personal data, but not delete it; and
(vii) Right to data portability – meaning that you may request that VitaMine provides you with a copy of your personal data we process in order to fulfil an agreement with you, or based on your consent, in order to (if it is technically feasible) transfer your personal data to another data controller.
7.3 You will find more information about your rights stipulated in Sections 7.2(i) - 7.2(vii) at the webpage of Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) (“IMY”). webpage
7.4 If you feel that our processing of your personal data does not comply with GDPR, and applicable data protection legislation, you are entitled to lodge a complaint with the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten). You will find more information about your right to lodge a complaint at IMY’s webpage. webpage
7.5 Any requests by you as a data subject to us under this Privacy Policy shall be sent to us at: legal@getvitamine.com. Requests will be handled as soon as possible, but no later than within one (1) month from the date which VitaMine received the request.
- AUTOMATED DECISION MAKING
8.1 In some cases, we use automated decision-making if permitted by law or other regulation, if you have given your explicit consent thereto or if it is necessary to fulfil an agreement with you. You can always give us your opinion or challenge decisions based solely on automated processing, including profiling, if the decision generates legal consequences or otherwise has a similar significant impact on your situation. When we use automated decision making, we inform you about the decision factors used, what this means for you and what consequences it may have for you.
8.2 We use automated decision-making in the following situations:
Design and adaptation of the Product based on the health information you have provided to us with in the consultation on our Website. Collection of certain user-generated data and device information (e.g., technical information including IP address, login information, operating system and device, time settings, screen settings, language, cookies, which features and pages you used on the Website, etc.) to make marketing decisions or complete customer - and/or Product analysis.
8.3 More information about our processing of personal data can be found in the table in Appendix A, Section 2.
- CHILDREN
Our Service and our Products are directed and intended for individuals over the age of eighteen (18). We do not and will not knowingly collect information from any unsupervised person under the age of eighteen (18). If the terms in this Section 9 are not fulfilled, you may not use the Service or the Website.
- LINKS TO THIRD PARTY SITES
Our Website may contain links to third party sites. If you click on a third party link, you will be directed to that site. Note that these external sites are not operated by VitaMine and, therefore, we strongly advise you to review the privacy policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.
- COOKIES
VitaMine uses cookies on its website (www.getvitamine.com) for the purpose of providing and updating our Service and to improve the user experience. For information on how VitaMine uses cookies, we refer to our Cookie Policy. The latest version of the Cookie Policy will always be available on our Website: www.getvitamine.com, and we advise you to review it periodically for any changes.
- AMENDMENTS AND ADDITIONS
VitaMine has the right to amend this Privacy Policy from time to time without giving prior notice to such change. This may include amendments of current and future services. Should any amendment of the Privacy Policy require a message or consent according to existing law, you will be informed and given the opportunity to give you leave your consent. The latest version will always be available on VitaMine’s website (www.getvitamine.com) and we advise you to review the Privacy Policy periodically for any changes.
- CONTACT DETAILS
VitaMine is the personal data controller regarding the processing of your personal data in accordance with this Privacy Policy. VitaMine has a data protection officer and a customer service team which administer privacy and data protection enquiries. You can reach our team on the below mentioned e-mail address.
VitaMine complies with Swedish data protection laws.
NamE: GetVitamine Scandinavia AB
Reg.no: 559314-8736
Visiting address:
Östermalmsgatan 26 A
114 26 Stockholm
Stockholms county
E-mail: legal@getvitamine.com
APPENDIX A – DETAILS ON OUR PROCESSING OF YOUR PERSONAL DATA
1. The personal data VitaMine processes regarding our Users can be divided into the following main categories (i) contact information, (ii) identity and other regulatory information, (iii) sensitive personal data, (iv) information on Product orders, (v) payment and user information, (vi) marketing preferences, (vii) user generated data, (viii) device information, and (ix) contact with customer service and feedback. The following table sets out the specifics regarding the type of data of each such main category as well as how we will obtain it.
| CATEGORY OF PERSONAL DATA | TYPE OF PERSONAL DATA | HOW WE RECEIVE THE PERSONAL DATA |
| Contact information |
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| Identity and other regulatory information |
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| Sensitive personal data |
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| Information on Product orders |
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| Payment and user information |
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| Marketing preferences |
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| User generated data |
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| Device information |
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| Contact with customer services and feedback |
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2.We process personal data in accordance with this Privacy Policy for the purposes and on the legal basis as specified in the following table.
| PURPOSE | TREATMENT | CATEGORY OF PERSONAL DATA | LEGAL BASIS | STORAGE PERIOD |
| Registering you as a User / create a user account as well as administer and perform our Service in accordance with agreements with Users |
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Legitimate interest - we have in an assessment (in accordance with Article 6(1)(f) GDPR) determined that the processing is necessary in order to create a relationship with you.
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During the term of the agreement between you and VitaMine. When we no longer have a legal basis (i.e., if you withdraw your consent or if the agreement is terminated) or a legal obligation to process your personal data, we will delete or anonymize the personal data that we process for the relevant purpose. |
| Communicating with you in order to administrating and performing our Service, including providing you with information (not marketing) in an electronic format |
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Fulfilment of an agreement - the processing is necessary to fulfil our obligations pursuant to an agreement with you (Article 6(1)(b) GDPR). You will find the general terms and conditions for the Service here. Explicit consent - to the extent that we process sensitive personal data (which you have provided through the consultation on the Website), our processing is based on your explicit consent (Article 9(2)(a) GDPR). |
During the term of the agreement between you and VitaMine. When we no longer have a legal basis or a legal obligation to process your personal data, we will delete or anonymize the personal data that we process for the relevant purpose. |
| Transfer of your personal data to payment service providers and other financial institutions (see Section 4.2.2) |
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Fulfilment of an agreement - the processing is necessary to fulfil our obligations pursuant to an agreement with you (Article 6(1)(b) GDPR). You will find the agreement / general terms and conditions for the Service här. Explicit consent - to the extent that we transfer sensitive personal data (i.e., your health information which you have provided in the consultation on the Website), to recipients according to this purpose, our processing is based on your explicit consent (Article 9(2)(a) GDPR). . |
Primarily when the purchase is performed but also during the period VitaMine have your data in our systems, i.e., until the data is deleted. More information regarding our rights and obligations to save your personal data is set out in Section 6. |
| Transfer your personal data to suppliers, sub-suppliers, partners with whom we collaborate, companies within the VitaMine group, professional advisors and authorities (the purpose varies depending on the recipient, see Section 4.2.) |
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Varies depending on the relevant third party (see Section 4.2). | Throughout the time that VitaMine has the data in its systems, for example to fulfil the agreement with you or to comply with the applicable law. More information regarding our rights and obligations to save your personal data is set out in Section 6. |
| Transfer of your personal data to partners with whom we collaborate within the framework of the Service according to Section 4.2.8 |
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Fulfilment of an agreement – necessary to fulfil an agreement with you (Article 6(1)(b) GDPR). Explicit consent - to the extent that we transfer sensitive personal data (i.e., your health information which you have provided through the consultation on the Website), to recipients according to this purpose, our processing is based on your explicit consent (Article 9(2)(a) GDPR). |
During the term of the agreement between you and VitaMine. When we no longer have a legal basis (i.e., explicit consent or agreement) or a legal obligation to process your personal data, we will delete or anonymize the personal data that we process for the relevant purpose. |
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Evaluating, analysing and improving our Service, Website, Products and system in general. |
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Legitimate interest – we have in an assessment (in accordance with Article 6(1)(f) GDPR) determined that the processing is necessary in order to fulfil our interest of evaluating and improving our Services, Products, Website, systems, assortment, business etc. We ensure that the processing hereunder is necessary to achieve the purpose and our interest overrules your right not to have your data processed for this purpose. By anonymizing data concerning you, we also ensure that we use personal data to an extent as minimal as possible. If you prefer more information about how the assessment has been made, you can always contact us (see our contact details in Section 13 ). Explicit consent (to the extent sensitive personal data occurs) – we anonymize your sensitive personal data (which you provided in the consultation on the Website), based on your explicit consent (Article 9(2)(a) GDPR). |
During the time that we have to keep your personal data in our systems, for example to fulfil the agreement with you, comply with the applicable legislation and as long as the consent is not revoked (as regards sensitive personal data), etc. More information regarding our rights and obligations to save information can be found in Section 6. |
| Sending newsletters, information, offers and marketing of our Service and Products. |
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Legitimate interest – we have in an assessment (in accordance with Article 6(1)(f) GDPR) determined that the processing is necessary in order to carry out our interest to market our Services, provide you with information offers etc. (which you at any time may object to). Explicit consent - we will obtain your explicit consent to provide you with newsletters, offers etc. if required by us pursuant to applicable marketing legislation. |
During the term of the agreement with you or when you inform us that you no longer have an interest in this type of processing / withdraw your consent. |
| Fulfilling our legal obligations, strive to prevent crimes, investigate whether a crime has been committed towards us, and safeguarding our interests in a dispute |
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Fulfilling a legal obligation – necessary pursuant to applicable law (Article 6(1)(c) GDPR) e.g., money laundering legislation, accounting legislation and tax legislation. If the relevant personal data is not processed by us, we cannot fulfil our legal obligations. Legitimate interest (if the above is not applicable) – we have in an assessment (in accordance with Article 6(1)(f) GDPR) determined that the processing is necessary in order to prevent abuse or misuse of our Service, prevent and investigate crimes towards us and safeguard our interests in the event of a dispute. |
During the time we have the data in our systems, for example to fulfil the agreement with you or in order to fulfil a legal obligation. More information regarding our rights and obligations to save information can be found in Section 6. |
| Administrating and performing merger, acquisition, reorganisation, reconstruction, asset transfer (including our customer and user database) or similar processes where we and/or our customer data and user base is the target, meaning that we may share your data with external parties according to Section 4.2.7 (i.e., potential buyers of the business or assets) |
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Legitimate interest – we have in an assessment (in accordance with Article 6(1)(f) GDPR) determined that the processing is necessary in order to facilitate an acquisition or reorganisation process. I.e., we have assessed that our interest to do so is overridden by your legitimate interests and rights of not having the data processed. However, such transfer of your personal data requires the overtaking party is conducting similar activities as VitaMine. We make sure that the processing this entails is necessary in order to fulfil the relevant interest. You have a right to object to this type of processing, due to circumstances in each relevant case. If you prefer more information about how the assessment has been made, you can always contact us (see our contact details in Section 13 ). Explicit consent - to the extent we share sensitive personal data (i.e., data you have provided in the consultation on the Website) to external parties pursuant to this purpose, such processing is based on your explicit consent (Article 9(2)(a) GDPR). |
During the time VitaMine have your personal data in its systems, for example to fulfil the agreement with you, in order to fulfil a legal obligation, and/or as long as the consent is not withdrawn (as regards sensitive personal data). More information regarding our rights and obligations to save information can be found in Section 6. |
| Generate anonymized reports regarding the general state of health for the purpose of transferring this to collaboration partners who are in need of such general information |
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Explicit consent – we anonymize your sensitive personal data (which you have provided through the consultation on the Website) based on your explicit consent (Article 9(2)(a) GDPR). Legitimate interest (to the extent explicit consent is not required) – VitaMine have in an assessment of interest (in accordance with Article 6(1)(f) GDPR) made the assessment that we have a legitimate interest to anonymize personal data for operational purposes and to generate an anonymized report. |
During the term of the agreement between you and VitaMine. When we no longer have a legal basis (i.e., explicit consent or agreement) or a legal obligation to process your personal data, we will delete or anonymize the personal data that we process for the relevant purpose |
APPENDIX B - THIRD COUNTRY TRANSFER
1.1 VitaMine transfers personal data, in accordance with Section 5 of the Privacy Policy, to the following Third Countries (i.e. countries outside the EU/EEA), based on the referred to appropriate safeguard according to GDPR:
Great Britain – the country is subject to an adequacy decision pursuant to GDPR Article 45, and we therefore do not take any further steps pursuant to GDPR Article 45 specifically, other than continuously monitoring that the adequacy decision remains in force.
1.2 In the event of a missing adequacy decision by the Commission pursuant to GDPR Article 45 for the transfer to a Third Country, we will always take additional appropriate safeguards before any transfer of personal data to the Third Country in question. However, this is based on the condition that the User's statutory rights and effective legal remedies are available to the User.
1.3 For more information on our practices in connection with transfers to Third Countries, contact us at legal@getvitamine.com
Privacy Policy VitaMine v.2023.01
Updated 2023.04