Last revised: May 2018
Renew Life UK (collectively, “we,” “us,” “our”) provides this Privacy Statement to inform you of our practices regarding the collection, use and disclosure of information that you provide to us or that we collect from you through our websites, our social media pages that we control from which you are accessing this Privacy Statement, and other online or mobile services, applications or advertisements that link to this Privacy Statement (collectively hereinafter, our “Properties”). Before using our Properties or providing information to us, please carefully review this Privacy Statement. By using one of our Properties, including registering for an account or accessing one of our Properties, you agree that we may collect and use your information in accordance with this Privacy Statement, as revised from time to time.
What’s Contained in this Privacy Statement
- What Information We May Collect
- How We May Use the Information We Collect
- Information Sharing and Disclosure
- Interest Based Advertising
- Retention and Storage of Personal Information
- Accessing and Updating Your Personal Information
- Opting Out of Communications
- Websites Not Covered by this Privacy Statement
- Cross-Border Data Transfers
- Contacting Us
- Changes to this Privacy Statement
What Information We May Collect
We aim to provide you information about how your personal information may be used at various data collection points throughout our Properties. The types of information we may collect about you include:
- Personal information is information that relates to an identified or identifiable individual. We may collect personal information through your use of the Properties, such as when you register for our Properties, subscribe to receive our communications, update your account information, enter contests or sweepstakes, respond to surveys, rate or review products, make purchases, contact us with questions or comments, apply for a job, connect with us through social networks, submit user generated content or participate in our online forums, promotions and social media platforms. In addition, if you elect to connect your social media account to your website account, certain personal information from your social media account may be shared with us, which may include personal information that is part of your profile or your friends’ profiles.
- We may collect and process your personal information in order to provide you with requested services related to our Properties, or because we are legally required to do so. Providing your personal information to us is voluntary, however, if you do not provide some or all of the information we request, we may not be able to provide you with certain products, services, or information.
- This personal information can include data attributes like your full name, username, password, email address, telephone number, physical or billing mail addresses, date of birth and other information you may provide to us, as well as credit card numbers or, in some limited cases national ID numbers. It may also include other personally identifiable information we have collected from you, such as your attitudes and opinions about and usage of our products, demographics, interests, household or lifestyle information, job description, satisfaction with our website and newsletters, your purchasing behavior or history and your browsing, downloading and other internet activity. Additionally, it may include a resume or curriculum vitae or other information you submitted in connection with a job application or inquiry. If you have contacted us on behalf of a business or other entity, we may also collect your work contact information and details about your business or entity that you provide to us.
- In some instances, we may combine your personal information with other information about you, such as combining your name with your geographic location or your browsing or purchasing history. We also may combine personal information with information we receive about you from outside sources. For example, we may obtain commercially available demographic information about you from third parties, receive device information from mobile applications or advertisements, match your profile with information about you provided by retailers or data brokers, or purchase e-mail or similar lists from third parties for advertising and marketing purposes.
- If you disclose any personal information relating to other people to us or to our service providers in connection with our Properties, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.
Device information we collect through our Properties:
We may collect device information in a variety of ways, including:
- Server log files: An Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider and is identified and logged automatically in our server log files whenever you visit one of our Properties, along with the time of the visit and the page(s) that were visited. We may use IP addresses for purposes such as routing visitors to the appropriate website for the visitor’s country, calculating usage levels, helping diagnose server problems, and administering our Properties. If you accessed one of our Properties using a mobile device like a smartphone, we may also collect your phone’s unique device ID and other similar mobile device data.
- Your use of software application(s): When you download and use applications made available by us for use on or through computers and mobile devices, we and our service providers may track and collect application usage data, such as the date and time the application on your device accesses our servers and what information and files have been downloaded to the application based on your device number.
- Cookies and similar technologies: A “Cookie” is a small text file containing a random and unique alphanumeric identifier that our Properties may transfer to your computer’s hard drive through your web browser that enables our systems to recognize your browser. We may employ technologies like Cookies, web beacons, clear GIF, pixel or Internet tag technologies to uniquely identify your account, or the IP address associated with your Internet device. We may also permit third parties to gather information on our websites, including for advertising purposes, through these technologies, as described below. Cookies and the other technologies mentioned above provide information related to the ways consumers interact with our advertising or our Properties, like browser type, browsing behaviors, user web requests, pages and content viewed, the number of new visits or log-ins, search engine referral, affiliate referrals, traffic driven by banner ads or other promotions, which items are placed in shopping carts and which are abandoned, conversions and what purchases were made and zip codes. These technologies can contain or store personal and other information (such as if you have previously registered on our Properties or consented to the retention of certain personal information) and allow web browser servers to recognize return visits to our Properties and improve web browsing navigation or the quality and delivery of certain features or customized content through our Properties. Some Cookies (known as “persistent cookies”) will remain on your computer or Internet device until you delete them, while others (known as “session cookies”) are automatically erased when you exit your Internet browser. You can set your computer or Internet device to accept or reject most Cookies, or to notify you in most situations that a Cookie is offered so that you can decide whether to accept it. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for more information. Some of our Properties also offer a “cookie consent” tool that allows you to block Cookies. However, if you block Cookies, certain features on our Sites may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.
- Flash LSOs: We and our third-party service providers may use Flash Local Storage Objects (“Flash LSOs”) in certain situations, including to recognize you and remember your preferences or other details about your visit. Flash LSOs are different from browser Cookies because of the amount and type of data stored. In addition, you generally cannot control, delete or disable the acceptance of Flash LSOs from your browser. For more information on Flash LSOs, and to learn how to control them, click on the support page for your Flash player and choose Global Storage Settings Panel and follow the instructions. To see the Flash LSOs on your computer now, go to your Flash player’s Website Storage Settings Panel and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
- Third-party applications and APIs: We may also offer and deliver services, content or interactive features through and/or using third party application programming interfaces (API), gadgets, extensions that are hosted on our Properties or through other third party websites, or social networking platforms. When you participate in these services, and subject to your consent where required by applicable law, products, applications, or otherwise connect with, or “accept” or “allow” third party applications, networks, platforms or services through our Properties and/or one of our services or products, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third party network or platform. Any personal or other information we receive by these means will be treated and/or processed according to this Privacy Statement.
- Location data: Some of our Properties may allow you to submit information about your general location, such as your zip code or address, in order to locate stores that sell our products or provide other location-related services. With your consent, some of our Properties also may capture and record certain precise geo-location or global positioning data from your device in order to provide location-related functionality. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Properties. If we combine any location information with personal information, we will treat the combined information as personal information as long as it is combined.
Aggregate and statistical information we collect through our Properties:
- De-identified information: We may conduct surveys and otherwise collect information that does not uniquely identify any individual. This might include demographic information like age and income range, gender, education, household size and marital status, as well as information from which identifying particulars have been removed. We also may aggregate personal information in a manner that no longer reveals your identity. We may collect, use and disclose such information for any purpose, such as research to improve our products or advertising.
- We may use and disclose this aggregate and analytics data for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine this information with personal information. If we do, we will treat the combined information as personal information as long as it is combined.
How We May Use the Personal Information We Collect
We may use the personal information we collect about you for our legitimate business interests, such as to:
- complete transactions you have requested or fulfill orders you have placed;
- respond to or follow-up on your comments, reviews, inquiries and other requests;
- deliver targeted advertising, communications, product solutions or content, as well as services you have requested;
- conduct research and analysis related to our business, products or Properties;
- improve or modify our products, services or Properties and tailor them to your usage or preferences;
- communicate with you about contests, sweepstakes, loyalty or rewards programs, coupons, rebates, promotions or other matters which you have entered or joined or for which you have requested information;
- implement social networking features you have activated;
- publish your reviews, comments, photos, videos and other content you have posted to one of our interactive or user-generated features;
- communicate with you about your account or your use of our Properties;
- if you have opted-in to receive news, special offers or other information from us or one of our brands by email or text message, send you promotional messages we think will be of interest to you. If you no longer want to receive these direct marketing communications, you may opt-out of such communications by the methods describe in the “Opting Out of Communications” section below.
Information Sharing and Disclosure
We may share your personal information with service providers, retail partners and other third party business partners (and their service providers), such as in the following circumstances:
- to conduct research and/or analysis regarding products, consumers and other matters;
- to allow us to better understand your interests, activities, demographics and profile;
- to prevent such parties from sending promotional messages on our behalf to people who have asked us to not send such messages; or
- if you have opted-in to receive promotional communications from us, send a tailored promotional communications to you jointly offering a product or service.
We will require these parties to maintain the confidentiality of your personal information, and will not authorize them to use the personal information we provide for their direct marketing purposes, unless you have opted-in to such disclosure and use.
We may rely on third party service providers to perform a variety of services on our behalf, and we may disclose your personal information to such service providers, such as fulfillment services, sweepstakes and contest administrators, loyalty and rebate program operators, technical support providers, customer service providers, delivery services, e-commerce providers, credit card processers and research and analytics providers. However, we do not authorize these third parties to use your data for purposes other than for which it has been provided, and do not authorize these third parties to disclose that information to unauthorized parties or use that information for their direct marketing purposes.
Additionally, we may use and disclose personal information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
We may share aggregated, statistical or anonymous information that does not identify you with third parties. For example, we may disclose the number of visitors to our websites, the number of people who have downloaded a particular coupon or the number of people from a certain state who purchased a product from one of our e-commerce websites.
Retention and Storage of Personal Information
We may retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide services to you through our Properties; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). We seek to use secure methods to destroy personal information including the use of reasonable technical and physical security measures to avoid unauthorized access to or use of the personal information after it is disposed.
Accessing and Updating Your Personal Information
If you have created an online account on one of our websites and would like to update the personal information you have provided to us, you can access your account on the applicable website to view and make changes or corrections to your personal information. You may also contact us using the methods described below under “Contacting Us” to request access to your personal information, to be informed of personal information that we hold about you, to have inaccurate personal information updated, corrected or removed, to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), and to object to the processing of your personal information to the extent permitted by applicable law. We will try to respond to your request as soon as reasonably practicable and in any case in compliance with applicable regulations.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed
Opting Out of Communications
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email newsletter you receive from that brand, or, if you created an online account when you registered to receive our emails, you may log-in to your account on our website and make changes to your communication preferences. If you no longer want to receive promotional text messages from one of our brands, please follow the cancellation instructions contained in the last text message sent by that brand. If you are having difficulty unsubscribing from our marketing communications using the above methods, please contact us directly using the methods listed below under “Contacting Us.”
We seek to use commercially reasonable organizational, technical and administrative means intended to protect stored and transmitted information from loss, misuse and unauthorized access or disclosure. However, no method of Internet transmission or electronic storage is 100% secure or error-free, so we, unfortunately, cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately in accordance with the “Contacting Us” section below.
Websites Not Covered by this Privacy Statement
Our Properties may contain links or references to other websites or services that are managed by third parties or that are managed by us but contain a different privacy statement. This Privacy Statement governs only information that we collect through our Properties that link to this Privacy Statement, and not to websites, services or applications that do not link to this Privacy Statement or that are maintained and controlled by other companies or organizations, including third party websites linked to from our Properties, as well as communications from third parties that reference our company or products.
Please note that many of the websites we operate outside of your home country may be governed by separate privacy policies linked to from those websites. This Privacy Statement also does not cover the “offline” collection of information by us from you unless you have been notified that this Privacy Statement applies at the time of collection.
The collection and use of your information by and through third party websites, applications or other means will be governed by the privacy policies applicable to those third parties and mediums. We are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with software applications or social media pages.
The inclusion of a link or reference on the Properties does not imply endorsement of the linked site by us or by our affiliates. Websites may contain our name, logos, products or other branding even though they are actually operated by third parties that may or may not have a relationship with us. Therefore, we encourage you to read the privacy statement of every service, application, or website you visit or interact with.
Our Properties are not intended for children under the age of 18 and we do not knowingly collect personal information from children under age 18. Children under the age of 18 should not use our Properties and should not provide their personal information to us.
Cross-Border Data Transfers
Because we operate globally, your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our Properties, you consent to the transfer of information to countries outside your country of residence, including the United States, which may have different data protection rules than in your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your personal information. You may obtain a copy of these measures by sending your request to us using the details in the “Contacting Us” section below.
We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Properties or otherwise to us.
CBee (Europe) Limited , located at Eton House – 2nd Floor, 18-24 Paradise Road, Richmond, TW9 1SE, UK, is the company responsible for collection, use and disclosure of your personal information under this Privacy Statement.
Please direct any inquiries related to this Privacy Statement or personal information we have collected about you to our Privacy Team by completing this online form. If you have any questions or comments about our company or our products or have other customer service needs, please click here for information on contacting our consumer service representatives.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
You may lodge a complaint with a supervisory authority competent for your country or region. Please click here for contact information for such authorities.
Changes to this Privacy Statement
We may update this Privacy Statement from time to time to reflect changes to our practices, technology, legal requirements and other factors. Please check the “Last Revised” legend at the top of this page to see when this Privacy Statement was last revised. When changes are made to this Privacy Statement they will become immediately effective when published in a revised Privacy Statement posted on this page unless otherwise noted. Your use of the Properties following these changes indicates your consent to the practices described in the revised Privacy Statement.