Fair Processing Notice
This fair processing notice sets out how HNC Healthy Nutrition Company (UK) Limited (“HNC”) uses and protects any information that you provide to us about yourself when you use the Maxinutrition.com website or that you otherwise provide to HNC.
HNC is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using the website, you can be assured that it will only be used in accordance with this fair processing notice.
HNC may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. If you are not, you should contact us at email@example.com.
This policy is effective from 29 March 2018.
What we collect
We collect personal information, which is information, that alone or with other information, relates to you (“Personal Data”). We collect this information when you provide Personal Data to us, via the website or other method of communication, and we may collect Personal Data about you from third parties whom we have contractual relationships with and who assist us with our website and logistics.
This Personal Data may include:
• your name
• your contact information including email address
• demographic information such as your postcode, preferences and interests
• other information about you relevant to customer surveys and/or offers
• information about your web browser and certain cookie information (see below).
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
• internal record keeping
• to deliver products or services to you
• to deal with any queries which may relate to those products or services, our website or our marketing
• to improve our products and services
• to predict other products and services which you may like, based upon your browsing history, profile and prior purchases
• to send you emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided
• to contact you for market research purposes by email, phone, fax or mail
• to respond to your requests or queries and improve the content of our communication.
Before contacting you for marketing or other related purposes we will respect any choices that you have made as to whether you wish to receive that marketing.
Sharing Your Personal Data with third parties
Sometimes we use and share your information with selected third parties to provide support services in connection with our website and in the normal course of business (“Service Partners”). These Service Partners include Red Eye International Limited (digital marketing services), Red Technology Solutions Limited (e-commerce services), CyberSource Limited (payment service provider), Bougheys Distribution Limited (fulfilment provider) and their affiliates as may be necessary.
We may also share your Personal Data with our affiliates, contractors and agents in the normal course of business for delivery of the activities to which you have agreed. Unless otherwise agreed by you, we will not sell or rent Personal Data to other third parties, except that your Personal Data may be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred. We may use your Personal Data to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
We also automatically collect information about your computer browser type and operating system, websites you visited before and after visiting our website, standard server log information, Internet Protocol (IP) addresses, GPS location data, mobile phone service provider and mobile phone operating system. We aggregate this information to understand how our visitors use our websites and mobile applications so that we can improve them and the services we offer. GPS location data does not typically identify individual users. We may also share this aggregated information with other companies within the group of companies of which HNC forms a part and with our Service Partners. This information includes:
• the total number of visits to our websites and mobile applications
• the number of visitors to each page of our websites and mobile applications
• the domain names of our visitors' internet service providers.
How we protect your Personal Data
We are committed to ensuring that your Personal Data is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information that we collect online.
HNC will take appropriate legal, organizational and technical measures to protect your personal information consistent with applicable privacy and data security laws. When HNC uses a third-party service provider (including a Service Partner), that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of Personal Data. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorised access, use or disclosure. Unfortunately, the transmission of information via the Internet or a mobile phone network connection is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of the Personal Data you transmit to our websites: any transmission is at your own risk. While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will employ appropriate technical security measures to prevent such unfortunate occurrences.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this fair processing notice. You should exercise caution and look at the fair processing notice applicable to the website in question.
When we may disclose your Personal Data to others
HNC reserves the right to disclose personal information about you, including your e-mail address, for reporting to government authorities, to parties in relevant legal proceedings as authorised by the presiding court or tribunal and otherwise to the extent required or explicitly authorised by applicable law. In certain special cases where permitted by local law, we may disclose your Personal Data:
• when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with HNC's rights, property or operations, other users of this website or mobile application or anyone else who could be harmed by such activities
• when we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation or civil or administrative authorities in connection with a pending civil case or administrative investigation
• in connection with a substantial corporate transaction, such as the sale of a product line or division, a merger, consolidation, asset sale or in the unlikely event of bankruptcy.
Personal Data collected may be transferred to, stored and processed in your country of residence or any other country in which HNC (including its affiliates), subcontractors or agents maintain facilities, including the United States and countries outside the European Economic Area (EEA). This means that your information may be processed in countries with lower data protection standards than your country of residence. By using our website, you consent to any transfer, processing or storing of your Personal Data outside of your country of residence and outside the EEA. We will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this fair processing notice.
Use of IP addresses
An IP address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your organisation's local area network (LAN) or wide area network (WAN). Web servers automatically identify your computer by the IP address assigned to it during your session online.
Controlling your Personal Data
You may choose to restrict the collection or use of your Personal data in the following ways:
• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us at the address given below or changing the direct marketing settings in your account.
• If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
If you wish to exercise any of your rights under applicable data protection law, or have any queries about this policy or the way we handle or process your Personal Data, please write to us at HNC Healthy Nutrition Company (UK) Limited at 17 Crescent, Salford M5 4PF, by phoning us on UK 0161 7363260 or, or by emailing us at firstname.lastname@example.org.
We will attend to your requests promptly and within any timescales prescribed by applicable law.
Using of Google analytics
Additional Notice to Existing Customers and Contacts
The Maxinutrition.com website was previously owned by GlaxoSmithKline Consumer Healthcare (UK) Limited (“GSK”). As such, Personal Data was previously collected by or on behalf of GSK in connection with the business for developing, promoting, advertising, manufacturing, distributing and selling MaxiNutrition and MaxiMuscle branded products (the “Maxi Business”). On [29 March 2018] HNC acquired certain assets of the Maxi Business from GSK and, as part of that acquisition, GSK has agreed to transfer the database of consumer and marketing records concerning the Maxi Business (the “Business Data”) to HNC. As a result, some of this Business Data with be held on the databases of both GSK and HNC and thus become so-called “Shared Data”.
As between the parties, HNC is now a data controller together with GSK of both the Business Data and of the Shared Data. However, GSK will remain a data controller of the Business Data only for the purposes of:
• transferring this Business Data to HNC
• dealing with any complaints or responding to you in connection with your rights as a data subject under applicable data protection legislation, insofar as these relate to the acts or omissions of GSK on or before [29 March 2018].
Both the Business Data and the Shared Data will be processed in [accordance] with this fair processing notice, including processing in connection with the sale of the relevant assets from GSK to HNC and processing in connection with the Maxi Business.
If you have any queries about how your Personal Data will be processed by HNC, please contact us at the address given above.
If you have any queries about how your Personal Data will be processed by GSK, please contact them at GSK 980 Great West Road, Brentford, Middlesex, TW8 9GS.