EternaLife Privacy Policy

Last Updated: Martch 29 th, 2024

Introduction

Welcome to EternaLife Limited’s Privacy Policy.

EternaLife respects your privacy and is committed to protecting your personal information. This Privacy Policy will inform you as to how we look after your personal information when you

  • visit our website (regardless of where you visit it from);
  • give consent to third parties to provide your personal information to us, or
  • provide information to us instore

and tell you about your privacy rights and how the law protects you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

1. Important information and who we are
PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how EternaLife collects and processes your personal information through your use of this website or when you provide information in store, including any data you may provide when purchasing a product or service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

CONTROLLER

EternaLife Limited, company number 14775595, registered office address 85 Great Portland Street, First Floor, London, England, W1W 7LT, United Kingdom

EternaLife Limited is the controller and responsible for your personal information (collectively referred to as ”EternaLife”, “we”, “us” or “our” in this privacy notice). EternaLife Limited is the controller and responsible for this website.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on March 29-th, 2024 and historic versions are archived

It is important that the personal information we hold about you is accurate and up to date. Please let us know if your personal information changes during your relationship with us. You can update your information at any time by amending your personal information within the Your Account section at EternaLife.co.uk.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal Data, or Personal Information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, gender, title, date of birth, email address.
  • Contact Data includes billing address, delivery address, email address and telephone number.
  • Financial Data includes bank account and payment card details.
  • Genetic Data includes information regarding your genotype (e.g., the As, Ts, Cs, and Gs at particular locations in your DNA) and length of your telomeres.
  • Health Data includes your disease conditions and genetic traits.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services, your browsing activity including intended purchases and aborted baskets, completion of surveys, wish-lists, connection information and statistics on your visits to site and page views, the links you click and other actions you take on our services, within our advertising or e-mail content and participation in promotional activity. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Unless you are an EternaLife user, we do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership). Nor do we collect any information about criminal convictions and offences.

Unless you are a EternaLife user, we do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect Personal Information 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 a product or service you have with us but we will notify you if this is the case at the time.

3. How is your Personal Data collected

We capture, process and retain Personal Information from you and any devices you may use when you navigate to a EternaLife.co.uk web or mobile view, by transacting, by registering an account and otherwise interacting with us. We may also collect Personal Information from you if you physically enter into one of our stores or attend an event.

Furthermore, we obtain your Personal Data from your healthcare specialist or treatment facility based on the consent you grant them, authorizing the transfer of your Personal Data to us.

We may capture customer information, purchase data and browsing behaviour as part of the rewards for life loyalty programme. This is so we can optimise and personalise your experience with EternaLife.co.uk.

Some more examples of the different methods by which we collect information from and about you include through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you
    • register or purchase our products or services through the site or mobile app;
    • return a product to store;
    • create an account on our website;
    • subscribe to our services or publications;
    • request marketing to be sent to you;
    • contact our customer service team;
    • enter a competition, promotion, survey or complete a questionnaire; or
    • give us feedback
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies. These machine learning algorithms generate content which they apply to personalising your experience and select more specifically the items you have an interest in as well as supporting general service optimisation including bid/ markdown automation. You may find more information of the use of cookies below in our Cookie Policy
4. How we use your Personal Data

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information 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. Please see point 5 below (Purposes for which we will use your Personal Information) to find out more about the types of lawful basis that we will rely on to process your Personal Information.

Please see point 5 below (Purposes for which we will use your personal information) to find out more about the types of lawful basis that we will rely on to process your personal information.

5. Purposes for which we will use your information

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

In general terms, we use the Personal Information we collect to help EternaLife Limited better understand you and to enable us to personalise your experience with EternaLife, including offers, promotions and services to meet your needs. We use your information to:

  • personalise our services, offers and promotions to you and provide you with a personalised experience on our sites;
  • process your online orders and in-store purchases;
  • offer you site content that includes items that you might like and to keep track of your basket;
  • contact you about your account and tell you about important changes at EternaLife Limited;
  • provide, develop and improve our products and services;
  • provide you customer service;
  • manage promotions, competitions, customer surveys and questionnaires;
  • check and verify your identity, and prevent, mitigate or detect and investigate crime, fraudulent or illegal activities; and
  • process purchases, payments, customer support and order fulfilment.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
(c) Special Categories of Personal information*
(a) Performance of a contract with you
(b) Consent
To provide services to you as defined in our Terms and Conditions (a) Special Categories of Personal information* (a) Consent
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Consent
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) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Consent
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 (to study how customers use our products/services, to develop them and grow our business)
(c) Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to prevent, detect, mitigate and investigate fraudulent or illegal activities (a) Identity
(b) Contact
(c) Technical
(d) Financial
(e) Usage
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and 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
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
(b) Consent
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Consent
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
(f) *Special Categories of Personal information
(a) Necessary for our legitimate interests (to develop our products/services and grow our business);
(b) In limited circumstances we rely on consent (see Promotional Offers From Us below)

* Special Categories of Personal Information include your Health Data and Genetic Data.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile, Health and Genetic 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). We will get your express opt-in consent before we use your personal information for providing you with promotional offers.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal information with any company outside the EternaLife Limited for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes at Your Account to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

CHANGE OF PURPOSE

We will only use your Personal Information 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.

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

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

6. Disclosures of your Personal Data

We may have to share your Personal Information with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary below.
  • External Third Parties as set out in the Glossary below.
  • 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 Information in the same way as set out in this Privacy Policy.

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

7. International Transfers

Many of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your Personal Information will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Information 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 Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe. For further details, see European Commission Standard Contractual Clauses (SCC).
  • Where we use providers based in the US, we may transfer data to them if they are part of the Data Privacy Framework which requires them to provide similar protection to Personal Information shared between the Europe and the US.
8. Data Security

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

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

9. Data Retention
HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In addition, this includes that we may retain Personal Information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your Personal Information, we dispose of it securely according to our data retention and deletion policies

When we determine the maximum retention duration of any Personal Data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Withdraw consent in section 10. Your Legal Rights below for further information.

In some circumstances we may anonymise your Personal Information (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.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. Please see below to find out more about these rights and access the request forms should you want to make any of these requests:

If you wish to exercise any of the rights set out above, please send the completed forms to us to the e-mail or postal address included on the form.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your Personal Information (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.

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 Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You can update your marketing preferences at any time by contacting us. Navigate to the Contact us section.

WHAT ARE YOUR RIGHTS

You always have the right to obtain a confirmation that your Personal Data is being processed, to access your Personal Data which is being processed or to require correction of inaccurate or incomplete data.


You shall also have the right to erasure (“right to be forgotten”) of your Personal Data on the grounds specified in the General Data Protection Regulation 2016//679. You can exercise the above mentioned rights at any time by contacting us. Navigate to the Contact us section.

Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. You can request restriction of processing by contacting us.

Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent at any time by contacting us.

11. Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

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 or regulatory obligation means processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
EXTERNAL THIRD PARTIES
  • Service providers acting as processors who provide IT, system administration services, payment providers to facilitate purchases, fulfilment providers to facilitate order management, packaging and delivery and marketing and communications services providers in order to personalise your experience and communicate with you.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators, law enforcement bodies and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances and otherwise in defence of legal claims.
  • Market researchers, fraud prevention agencies and analytics providers.
Contact Us

Our contact address is: 85 Great Portland Street, First Floor, London, England. you can email us at info@eternalife.co.uk.