Privacy policy

This Privacy Notice is applicable to your use of the www.liftglucose.com website. For other matters relating to Venture Life Healthcare Limited, its general privacy notice is applicable and can be found here

Venture Life Healthcare Limited (“VLH”); www.liftglucose.com

PRIVACY NOTICE

Under the UK GDPR’s General Data Protection Regulation (GDPR) ‘Personal Data’ is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

VLH respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will inform you as to how we look after your Personal Data, tell you about your privacy rights and how the law protects you.

IN THIS PRIVACY NOTICE, IF WE USE THE WORDS INCLUDING, INCLUDE, IN PARTICULAR, FOR EXAMPLE OR ANY SIMILAR EXPRESSION, WE ARE GIVING EXAMPLES AND THOSE WORDS SHALL NOT LIMIT THE SENSE OF THE WORDS, DESCRIPTION, DEFINITION, PHRASE OR TERM THAT FOLLOWS THOSE WORDS.

1.0     Purpose of this Privacy Notice

1.1       This Privacy Notice aims to give you information on how VLH collects and processes your Personal Data.

1.2       It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.

1.3       Where VLH or its subsidiaries act as a data Processor on the instructions of a data Controller, a separate Privacy Notice will be published by that data Controller, usually on the relevant domain and provided directly to the relevant data subjects.

2.0      Our Contact Information (Data Controller)

2.1       Venture Life Healthcare Limited of Venture House, Downshire Way, Bracknell, England, RG12 1WA with company registration number 05623945 is the Controller and responsible for your personal data (collectively referred to as Venture Life, the “Company”, “we”, “us” or “our” in this privacy notice). We are registered with the ICO with registration reference number ZB567288.  

Our contact information is as follows:

Data Protection Officer at dpo@venture-life.com

Venture Life Healthcare Limited

12 The Courtyard,

Eastern Road,

Bracknell,

RG12 2XB

United Kingdom

RG12 1WA

 Telephone: 01344 578004

 

Changes to the privacy notice and your duty to inform us of changes

We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective 26 September 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3.0       The data we collect about you

3.1       We collect, use, store and transfer different categories of Personal Data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers to be used in relation to orders you place with us and also online accounts and subscriptions you open and put in place with us.
  • Transaction Data includes details about online payments to and from you and other details of products you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or intranet.
  • Profile Data includes your username and password on our website, purchases or orders made by you, your preferences, and feedback, survey responses and the items added to your shopping basket.
  • Usage Data includes information about how you use our website and products.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

3.2       We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

3.3       Special Categories of Personal Data these are details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not normally collect any special categories of data nor do we collect any information about criminal convictions and offence. However if we do need to processes such data we will ask for your explicit consent to do so.

4.0       If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel an order for a product you have with us but we will notify you if this is the case at the time.

5.0       We use different methods to collect data from and about you including through:

5.1       Direct interactions. You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, phone, and e-mail or otherwise. This includes Personal Data you provide when you:

  • purchase our products;
  • create an account on our website;
  • obtain a subscription to our products;
  • request marketing to be sent to you;
  • enter a promotion or survey;
  • give us some feedback;
  • provide unsolicited information to us;

 

5.2       Automated interactions. As you interact with our website or intranet, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies.

5.3       Third parties (or publicly available sources). We may receive categories of Personal Data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google; advertising networks and search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services including e-commerce platform providers.
  • Identity and Contact Data from data brokers, aggregators, review providers, and courier/postal services and distributor providers.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.

 

6.0       How we use your Personal Data

6.1       We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

6.2       We may also use your Personal Data in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest or for official purposes.

6.3       Generally we do not rely on consent as a legal basis for processing your Personal Data other than, where we have not had any prior relationship with you and you have not opted out of such marketing, in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing to that email or text.  

6.4     In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

7.0       Purposes for which we will use your Personal Data

7.1       We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

7.2       Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need additional details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

 

Purpose/Activity

Category of Personal Data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer.

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Transaction

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

i)  to recover debts due to us.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Transaction

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests

i)  to keep our records updated,

ii)  to study how customers and clients use our products/services;  and,

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

i)  to study how customers use our products/services; and

ii)  to develop them and grow our business.

To administer and protect our business and our intranet and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(e) Usage

(a) Necessary for our legitimate interests

i)  for running our business relationship,

ii)  provision of administration and IT services, network security,

iii)  to prevent fraud,

iv)  in the context of a business reorganisation or group restructuring exercise.

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests

i) to study how customers use our products/services,

ii)  to develop them,

iii)  to grow our business and

iv)  to inform our marketing strategy.

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests

i)  to define types of customers for our products and services;

ii)  to keep our website updated and relevant;

iii)  to develop our business; and,

iv)  to inform our marketing strategy.

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests

i)  to develop our products/services; and,

ii)  to grow our business.

To use third party marketing platforms to obtain information regarding you as a customer in respect of your purchases and to measure and understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Necessary for our legitimate interests

i)  to study how customers use our products/services,

ii)  to develop them,

iii)  to grow our business and

iv)  to inform our marketing strategy.

To process the sales of goods throughout the lifecycle of your purchase, including payments, delivery, customer service and sales

(a) Identity

(b) Contact

(c) Transaction

(d) Profile

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

i)  for running our business relationship,

ii)  provision of administration and IT services, network security,

iii)  to prevent fraud.

 

 

8.0       Marketing

8.1       We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:

  • Promotional material from us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
  • You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have opted-in to receiving that marketing.
  • Third-party marketing.  We will get your express opt-in consent before we share your Personal Data with any company outside VLH for marketing purposes.
  • Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
  • Where you opt-out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty, product/service experience or other transactions.
  • Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To find out more information regarding the use of cookies, please visit our Cookies Policy. 
  • To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

 

9.0     Change of purpose

9.1     We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. To find out more about how the processing for a new purpose is compatible with the original, please contact our Data Protection Officer at the address listed in clause 2.

9.2     If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

9.3     Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

10.0     Disclosures of your Personal Data

10.1     We may have to share your Personal Data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties: other companies or departments in VLH acting as Processors or joint Controllers and provide IT and system administration services and undertake leadership reporting
  • External Third Parties: service providers acting as Processors based who provide IT and system administration services
  • Other Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.
  • Professional advisers: acting as Processors or joint Controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting and payroll services.
  • HM Revenue & Customs, regulators and other authorities acting as Processors or joint Controllers who require reporting of processing activities in certain circumstances.
  • E-Commerce Platform Service Providers, to provide e-commerce platform solutions.
  • Payment Service Providers, who are used to process customer payments for one-time and subscription purchases.
  • Law Enforcement Bodies, such as the ICO or National Crime Agency.
  • Logistics Providers, or other courier or postal services, used in order to process and ship your orders.
  • Third Party Advertisement Services, used for generating audience lists for marketing purposes.

10.2     We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

10.3    Please note that any reviews that you provide or surveys you complete where you do not anonymise your identity may be publicly published.

 

11.0     International transfers

11.1     In the ordinary course of business, your data will be processed in accordance with the UK GDPR and Data Protection Act 2018. However, some of our external third parties are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA.

11.2     Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US.

 

12.0     Data security

12.1     We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

12.2     We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

13.0     Data retention

13.1     We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

13.2     To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accountancy or other requirements.

13.3     In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

14.0     Your legal rights

14.1     Under certain circumstances, you have rights under data protection laws in relation to your Personal Data to request the following:

  • access to your Personal Data.
  • correction of your Personal Data.
  • erasure of your Personal Data.
  • object to processing of your Personal Data.
  • restrict of processing your Personal Data.
  • transfer of your Personal Data.
  • withdraw consent to any consent that you have previously given.

Further information can be found at paragraph 17.

 

14.2     You have the right to make a compliant at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection matters (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns you may have before you contact the ICO.

The ICO address is as follows:

Information Commissioners Office

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Phone: 0303 123 1113

14.3     You will not usually have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

15.0     What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

16.0     Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In the event that your request is deemed legitimate, we may require you to provide identification and/or documentation to prove your identity. Where you do not, there may be a failure or delay in responding to your request within one month.  

17.0     Glossary

Your Legal Rights means

  • Access to your Personal Data; you have the right to request a copy of the information we hold about you.
  • Correction of your Personal Data; you have the right to correct data that is inaccurate or incorrect.
  • Erasure of your Personal Data; you have the right to, in certain circumstances, ask for the data held about you to be removed from our records.
  • Object to processing of your Personal Data; you have the to, in certain circumstances, object to the processing of your Personal Data such us direct or third party marketing. 
  • Restrict of processing your Personal Data; you have the right to, in certain circumstances, restrict the processing.
  • Transfer of your Personal Data; you have the right to, in certain circumstances, restrict the transfer.
  • Withdraw consent to any consent that you have previously given; you have the right to object or withdraw consent at any time.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Personal Data has the meaning given to it at the beginning of this Privacy Notice.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.