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Privacy Policy

1. Our approach to privacy

1.1 At Elvie ("Elvie", "we", "our" or "us") we are as committed to protecting and respecting your privacy as we are to creating cutting edge, smart technology for women. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.
 

1.2 We operate the www.elvie.ae website, where you can view and order products, read updates and information about our products and women's health in general, and browse instructions and guidance on how to use our products (the "Site"). We also operate product specific apps that are available for download on your device, which can be paired to our products and, with certain products, are required to operate them as set out in the relevant product manual (the "Apps").
 

1.3 This Privacy Policy applies to the Site and our Apps. Please ensure that you have read this Privacy Policy and understood how we collect, store, use and disclose your personal information before accessing or using the Site or the Apps.
 

2. Who is responsible for the use of your personal information

2.1 Elvie is the trading name of Chiaro Technology Limited, which is the controller of the personal information we hold about you in connection with your use of the Site and the Apps. This means that we determine and are responsible for how your personal information is used.
 

3. Personal information we collect from you when you use the site, contact us or purchase products and how we use it

3.1 We collect personal information that you voluntarily submit directly to us when you use the Site. This can include information you provide to us when you order and pay for a product through our Site, correspond with us by phone, e-mail or otherwise in relation to the Site or our products, submit reviews or subscribe to our mailing lists, newsletters or other forms of marketing communications.

3.2 We will indicate to you where the provision of certain personal information is required in order for us to process your order, respond to your query or otherwise provide you with functionality of the Site. If you choose not to provide such personal information, we may not be able to process your order, provide support or respond to your other requests.

3.3 When you use the Site, the categories of information we collect may include:

a) the type and quantity of products you order;

b) your contact details, such as your name, email address and phone number;

c) your delivery address;

d) your payment details, such as your method of payment and billing address;

e) your preferences as to how we communicate with you and how our Site is displayed; and

f) the content of any queries or requests you submit to us.

We use this information to process any orders you place through our Site, to address your questions and concerns, to contact you and to help us develop new products and services.

3.4 Annex 1 sets out further detail about the categories of personal information we collect about you and how we use that information when you use the Site, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
 

4. Personal information we collect from you when you use our Products and Apps and how we use it

4.1 We also collect personal information that you voluntarily submit directly to us when you use our products and Apps. This can include information you provide to us when you set up an account on an App, or when you pair and use one of our products with the appropriate App.

4.2 We will indicate to you where the provision of certain personal information is required in order for us to provide you with certain features and functionalities of the Apps. If you choose not to provide such personal information, we may not be able to provide those parts of the Apps to you.

4.3 When you use the products and appropriate Apps, the categories of information we collect may include:

a) your name and email address;

b) your birth year and number of children;

c) information about how you use the product; and

d) your preferences about how we communicate with you and how the Apps are displayed. 

We use this information to provide you with the functionalities of our products and Apps, to provide you with customer support and for our research and development (including developing new products and services).

4.4 Annex 2 sets out further detail about the categories of personal information we collect about you and how we use that information when you use our products and Apps, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
 

5. Information we collect automatically about your use of our Apps and Site

5.1 We also automatically collect personal information indirectly about how you access and use the Site and our Apps, and information about the device you use to access the Site or the Apps. For example, we may collect: 

a) information about the features you use and the pages you view on the Site and the Apps;

b) information about your device (such as your IP address, device identifier, device type, model and manufacturer); and

c) information about your usage patterns (such as how often you use the Site or an App and your language settings).

We use this information to provide you with the features and functionality of the Site and the Apps, to monitor and improve the Site and the Apps and to develop new products and services.

5.2 Annex 3 sets out further information about the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information.

5.3 We may link or combine the personal information we collect about you and the information we collect automatically however, we will not process them without your consent. This allows us to provide you with a personalised experience regardless of how you interact with us.

5.4 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Site and our Apps and developing new products and features.
 

6. How long will we store your personal information

6.1 We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1, Annex 2 and Annex 3, in accordance with our legal obligations and legitimate business interests and in all cases in line with the relevant applicable laws in your jurisdiction. 

6.2 We may, however, need to retain your personal information for longer if we are required to do so by law.
 

7. Recipients of personal information

7.1 In addition to the recipients listed in Annexes 1, 2 and 3, we may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1, 2 and 3): 

a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services. 

b) Social media: we may use "lookalike" analytics functions, such as "Facebook Lookalike Audiences", to identify new potential customers on the basis that they might share some characteristics with you. If you interact with us through social media, such as if access our Site or download our Apps in response to an advert on a social media platform, we may therefore share your personal information with social media platforms to enable them to identify users similar to you, such as users that have liked the same pages or content as you.

c) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

d) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms and Conditions of Use and Terms and Conditions of Sale; and/or (iii) exercise or protect the rights, property, or personal safety of Elvie, its users or others.

7.2 Other than as set out above, we may also share statistics and insights developed by us from your personal information. These statistics and insights are derived from anonymised and aggregated information, such that it would not be possible to identify you (directly or indirectly) or even single you out from this information.
 

8. Marketing and Advertising

8.1 From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

8.2 Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

8.3 We will only send you marketing messages if you have given us your consent to do so. You can update your preferences about the emails you receive from us at a later date, including withdrawing your consent, by clicking on the link at the bottom of our marketing emails.
 

9. Storing and transferring your personal information

9.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

9.2 De-identification. When we collect personal information about your use of our products and Apps, we only store this information in a way that does not directly identify you. We will only re-identify you in exceptional circumstances, such as if we are required to do so by applicable law, if we need to conduct a product recall, or if you ask us to.

9.3 International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the UK or European Economic Area ("EEA"), your personal information may be processed outside of the UK or EEA including in the United States.

9.4 In the instance of such a transfer, we ensure that:

a) the personal information is transferred to countries recognised as offering an equivalent level of protection; or

b) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or UK Information Commissioner.

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.
 

10. Your rights in respect of your personal information

10.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

a) Right of access. You have the right to obtain: 

i) confirmation of whether, and where, we are processing your personal information;

ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

iii) information about the categories of recipients with whom we may share your personal information; and

iv) a copy of the personal information we hold about you. 

b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you. 

10.2 You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

10.3 If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

10.4 You may also review and edit some of the personal information you have submitted to us through the appropriate functionality on the Apps.

10.5 Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

10.6 We will seek to respond to any request relating to your rights within one month of receipt of such request.

10.7 Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, we will inform you of the extended deadline in which we will respond to your request. Such extension may not be more than two months from the date on which we notify you that an extension is required.

10.8 Where we do not follow up on your request, we will inform you within the one month deadline of the grounds on which we have based our decision and of your right to refer a complaint to your national data protection authority.
 

11. Cookies and Similar Technologies used on our website

11.1 Our Site uses cookies and similar technologies (such as Local Storage Objects, LSOs, scripts and pixels) to distinguish you from other users of our Site.

11.2 Traditional cookies are pieces of code that allow for personalisation of our Site experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.

11.3 Cookies and similar technologies help us to provide you with a good experience when you browse our Site and also allows us to monitor and analyse how you use and interact with our Site so that we can continue to improve our Site. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.

11.4 We use the following types of cookies:

a) Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to use a shopping basket or pay for products through our Site. 

b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

c) Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

d) Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.

e) Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Site. These third parties are responsible for setting out their own cookie and privacy policies. This Privacy Policy applies only to the personal information we collect on our Site. We encourage you to read the privacy policies of other websites you link to from our Site or otherwise visit.

11.5 Please see Annex 4 for more information about the cookies we use on the Site.

11.6 The cookies we use are designed to help you get the most from our Site but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Site. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, please use the "Help" option in your browser for more details.

11.7 Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs).
 

11.8 If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org.
 
12. Tracking Technologies used in our emails

12.1 Our emails may contain tracking technologies that provide us with information about your interactions with our emails, including identifying if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

12.2 Most popular email clients will allow you to block these technologies by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.

12.3 Some browsers also give you the option of downloading and installing extensions that block tracking technologies.
 

13. Interest Based Advertising

13.1 We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Site. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Site over time so that they may play or display ads of the Site, our products and services and similar products and services, on other websites, apps or services you may use (including Google and Facebook).

13.2 Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Site and information about which adverts you have seen or clicked on.

13.3 We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

13.4 We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Site.You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at www.networkadvertising.org/choices.

13.5 Chiaro Technology partners with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information is subject to the privacy policy located here. https://rakutenadvertising.com/legal-notices/services-privacy-policy

13.6 You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You may also be able to opt-out of some, , interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

13.7 To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:

a) the Network Advertising Initiative’s online resources, at www.networkadvertising.org/choices;

b) the DAA’s resources at www.aboutads.info/choices; and/or

c) Your Online Choices at www.youronlinechoices.eu

13.8 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.

13.9 Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.

13.10 Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.


14. Links to third party sites

14.1 The Site and our Apps may, from time to time, contain links to and from third party websites, including those of our partner networks, advertisers, partner merchants, news publications, and retailers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
 

15. Our policy towards children

15.1 Our Site and Apps are not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.


16. Changes to this policy

16.1 We may update this Privacy Policy from time to time so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the "last modified" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.


17. Notice to you

17.1 If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Site or our Apps. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
 

18. Contacting us

18.1 Please contact privacy@elvie.com if you have any questions, comments and requests regarding this Privacy Policy.

18.2 If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at https://u.ae/en/about-the-uae/digital-uae/data/data-protection-laws.

18.3 Should you wish to delete your personal data that we store, you can close your Elvie account by using the in-app account deletion function. Please note that this will delete your account and personal data across all Apps immediately and cannot be undone.  Alternatively, you can contact us at privacy@elvie.com.

18.4 This Privacy Policy was last modified on 25 October 2022.

 

Annex 1 - Personal information you provide to us when you purchase products, contact us or use our site

1. Contact information

Contact information such as your name, phone number, e-mail address and shipping address.

How we may use this information

We may use this information to process and ship the products you have ordered to you. The processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.

We may use this information to deal with any enquiries, support requests or complaints made relating to our Site or your product orders. The processing is necessary for our legitimate interests, namely administering the Site, and for communicating with you effectively to respond to your queries, support requests or complaints.

We may use this information to communicate with you, including sending service-related communications, such as updates about your order. The processing is necessary for the performance of a contract with you.

We may use this information to send you surveys or requests for feedback about your experience of the Site. We will only use your personal information in this way to the extent you have given us consent to do so.

We may use this information to send you unsolicited marketing communications in accordance with your preferences. We will only use your personal information in this way to the extent you have given us consent to do so.

Recipients of this information

We may share this information with:

  • our fulfilment partners, DXC Technology Company, Bleckmann Nederland B.V. and/or Synergy Retail Support Limited and their affiliates, in order to fulfil your order;

  • our distributors Lafta Trading Company LLC and Baby Friendly Trading L.L.C in order to process replacement units;

  • our marketing email service provider, The Rocket Science Group LLC d/b/a/ Mailchimp, in order to send you marketing and service-related communications;

  • our marketing and customer data platform providers, Ometria Limited and Mention Me Limited, in order to send personalised marketing and service-related communications;    

  • our direct mail partner, Inkpact, and their technology provider, Gateway Global Digital, in order to send personal letters to our customers;

  • our customer support management platform providers, Square Talk Ltd, NetSuite, Inc., Language IO, Inc. and Salesforce.com, Inc, in order to process any support requests or queries that you send to us;

  • our customer support management integration provider, Zapier, Inc, in order to connect and transfer data between our customer support management platform providers;

  • our payment services providers, PayPal (Europe) S.à.r.l. et Cie, S.C.A. (trading as Braintree), Amazon Payments and/or Klarna Bank AB and/or Klarna’s subsidiary BillPay GmbH (for Swiss transactions only), in order to process your payments. In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice;

  • our survey and review service providers, Bazaarvoice, Inc, Trustpilot.com and Delighted, LLC, in order to send you surveys and obtain your feedback in relation to our products and services.

  • our survey and forms providers, Typeform and Usersnap, in order to process and collect data collected from our surveys, online forms and guide you through troubleshooting, and process requests for replacement parts when necessary.

2. Transaction information

Transaction information such as the products you order from our Site, as well as the date and time of your transaction.

How we may use this information

We may use this information to process and ship the products you have ordered to you. The processing is necessary for the performance of a contract with you.

We may use this information to process any warranty claims you may submit to us, including the exercise of your rights under applicable law. The processing is necessary for the performance of a contract with you.

We may use this information to deal with any support requests in relation to the products you have ordered, including queries about the delivery process. The processing is necessary for our legitimate interests, namely providing customer support.

We may use this information to determine products and services that may be of interest to you. The processing is necessary for our legitimate interests, namely to inform our marketing.

We may use this information to identify fraudulent transactions. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

Recipients of this information

We may share this information with:

  • our fulfilment partners, DXC Technology Company, Bleckmann Nederland B.V. and/or Synergy Retail Support Limited and their affiliates, in order to fulfil your order;

  • our marketing and customer data platform providers, Ometria Limited and Mention Me Limited, in order to send personalised marketing and service-related communications; 

  • our customer support management platform provider, Salesforce.com, Inc, in order to process any support requests or queries that you send to us;

  • our customer support management integration provider, Zapier, Inc, in order to connect and transfer data between our customer support management platform providers;

  • our payment services providers, PayPal (Europe) S.à.r.l. et Cie, S.C.A. (trading as Braintree), Amazon Payments and/or Klarna Bank AB and/or Klarna’s subsidiary BillPay GmbH (for Swiss transactions only), in order to process your payments. In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice;

  • our survey and review service providers, Bazaarvoice, Inc, Trustpilot.com and Delighted, LLC, in order to send you surveys and obtain your feedback in relation to our products and services.

3. Payment information

Payment information, such as your credit or debit card, billing address, and other information such as date and time of your transaction.

How we may use this information

We may use this information to process the payments you make on the Site. The processing is necessary for the performance of a contract.

We may use this information to identify fraudulent transactions. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

Recipients of this information

We may share this information with:

  • our payment services providers, PayPal (Europe) S.à.r.l. et Cie, S.C.A. (trading as Braintree), Amazon Payments and/or Klarna Bank AB and/or Klarna’s subsidiary BillPay GmbH (for Swiss transactions only), in order to process your payments. In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

4. Correspondence, comments and opinions

Correspondence, comments and opinions. When you contact us directly, e.g. by email, phone, through our social media channels or when you complete an online form, we will record your comments and opinions.

How we may use this information

We may use this information to address your questions, issues and concerns. The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.

We may use this information to develop new products and features available on our Site or otherwise improve our Site. The processing is necessary for our legitimate interests, namely developing and improving our Site.

We may use this information to determine products and services that may be of interest to you. The processing is necessary for our legitimate interests, namely marketing.

We may use this information to send you solicited marketing communications and other information in response to your enquiries. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We may use this information to send you unsolicited marketing communications in accordance with your marketing preferences. We will process your personal information for this purpose to the extent that you have given us consent to do so.

Recipients of this information

We may share this information with:

  • our marketing and customer data platform providers, Ometria Limited and Mention Me Limited, in order to send personalised marketing and service-related communications;

  • our customer support management platform provider, Salesforce.com, Inc, in order to process any support requests or queries that you send to us;

  • Facebook Ireland Limited and its affiliates, if you contact us through Facebook messenger or via our Facebook page, in order to communicate with you;

  • Chiax LLC (trading as Statusbrew), if you contact us through our other social media channels, in order to communicate with you;

  • our survey and review service providers, Bazaarvoice, Inc, Trustpilot.com and Delighted, LLC, in order to send you surveys and obtain your feedback in relation to our products and services.

  • our survey and forms providers, Typeform and Usersnap, in order to process and collect data collected from our surveys, online forms and guide you through troubleshooting, and process requests for replacement parts when necessary.

5. Information received from third parties, such as social networks

Information received from third parties, such as social networks. If you interact with us through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.

How we may use this information

We may use this information to communicate with you and to address your questions, issues and concerns. The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.

We may use this information to inform our marketing, such as through "Facebook Lookalike Audiences". The processing is necessary for our legitimate interests, namely informing our direct marketing.

Recipients of this information

We may share this information with:

  • our marketing and customer data platform providers, Ometria Limited and Mention Me Limited, in order to send personalised marketing and service-related communications;

  • our customer support management platform provider, Salesforce.com, Inc, in order to process any support requests or queries that you send to us.

6. Your preferences and subscriptions

Your preferences and subscriptions, such as whether you have subscribed to any newsletters and your preferences set for notifications and marketing communications.

How we may use this information

We use this information to provide notifications, send news, alerts and marketing communications where you have asked us to do so, or where you have consented. The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications.

We use this information to ensure that we comply with our legal obligation to send only those marketing communications which you have requested or to which you have consented. The processing is necessary for compliance with a legal obligation to which we are subject.

Recipients of this information

We may share this information with:

  • our marketing and customer data platform providers, Ometria Limited and Mention Me Limited, in order to send personalised marketing and service-related communications.

7. All personal information

All personal information set out above.

How we may use this information

We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Site, to communicate with you, to monitor and improve the Site and our business, and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve the Site.

 

 

Annex 2 – Personal information we collect when you use our products and apps

 

1. Profile information

Profile information, such as your name and email address.

How we may use this information

We may use this information to set up and authenticate your account on the App. The processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.

We may use this information to communicate with you, including sending service-related communications. The processing is necessary for the performance of a contract with you.

We may use this information to send you unsolicited marketing communications in accordance with your preferences. We will only use your personal information in this way to the extent you have given us consent to do so.

Recipients of this information

We may share this information with:

  • our customer support management platform providers, Square Talk Ltd, Language IO, Inc. and Salesforce.com, Inc in order to process any support requests or queries that you send to us;

  • our customer support management integration provider, Zapier, Inc, in order to connect and transfer data between our customer support management platform providers.

2. Age and family history

Age and family history, such as the year you were born and the number of children you have had.

How we may use this information

We may use this information to personalise certain features of our Apps, such as the exercise routines recommended for you when you use Elvie Trainer. The processing is necessary for our legitimate interests, namely tailoring our products and Apps to you.

3. Usage information

Usage information, such as the time for which you use our products, your results when you use our products, any issues experienced when you use our products and any other information generated by the products about how you use our products.

How we may use this information

We may use this information to provide the functionalities of the Apps that allow you to monitor and view statistics about your use of the products. The processing is necessary for the performance of a contract with you.

We may use this information to analyse how our products perform, to fix issues with our products and Apps, to improve our products and Apps and develop new products and services. The processing is necessary for our legitimate interests, namely improving our products and services, dealing with any errors in our products and services and developing new products and services.

4. Your preferences and subscriptions

Your preferences and subscriptions, such as your preferences about how the App is displayed, whether you have subscribed to any newsletters and your preferences set for notifications and marketing communications.

How we may use this information

We use this information to customise how the Apps are displayed, the content available through the Apps, and to provide notifications, send news, alerts and marketing communications where you have asked us to do so, or where you have consented. The processing is necessary for our legitimate interest, namely tailoring our products to our users and ensuring the user receives the correct marketing and other communications.

We use this information to ensure that we comply with our legal obligation to send only those marketing communications which you have requested or to which you have consented. The processing is necessary for compliance with a legal obligation to which we are subject.

Recipients of this information

We may share this information with:

  • our marketing and customer data platform provider, Ometria Limited, in order to send personalised marketing and service-related communications.

 

Annex 3 – Personal information collected automatically when you use the site or the apps

1. Approximate location information

Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location.

How we may use this information

We may use information you provide to us about your location to inform and plan our marketing strategy and to monitor and detect fraud or suspicious activity in relation to your account. The processing is necessary for our legitimate interests, namely informing our direct marketing strategy.

We may use this information to tailor how the Site and the Apps are displayed to you (such as the language in which they are provided to you). The processing is necessary for our legitimate interest, namely tailoring the Site and the Apps so that they are more relevant to our users.

2. Information about how you access and use the Site and the Apps

Information about how you access and use the Site and the Apps. For example, how frequently you access the Site or the Apps, the time you access the Site or the Apps and how long you use it for, the approximate location that you access the Site or the Apps from, whether you access the Site or the Apps from multiple devices, and other actions you take on the Site or the Apps, such as what pages you view, any selections made and any information you enter into the Site and the Apps.

How we may use this information

We may use information about how you use and access the Site and the Apps to present the Site and the Apps to you on your device. The processing is necessary for our legitimate interests, namely to tailor the Site and the Apps to the user.

We may use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We may use this information to monitor and improve the Site, the Apps and/or our business, to resolve issues and to inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Site and Apps and to improve the Site and Apps generally.

3. Log files and information about your device

Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to access the Site or the Apps. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications that you use to access the Site and/or Apps on your device, your mobile network, your IP address and your device’s telephone number (if it has one).

How we may use this information

We may use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We may use this information to monitor and improve the Site, the Apps and/or our business, to resolve issues and to inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Site and Apps and to improve the Site and Apps generally.

Recipients of this information

We may share this information described in 1, 2 and 3 above with:

  • FullStory and Google LLC and its affiliate Firebase, which provide our analytics platforms, in order to help us understand how visitors use the Site and/or our Apps;

  • Facebook Ireland Limited and its affiliates, in order to support social sharing and the integration of Facebook services with our Site;

  • Facebook Ireland Limited, Google LLC, Outbrain UK Limited and Criteo S.A. and their affiliates who use information obtained from our Site to target and display customised ads to you when you browse the internet;

  • Ometria Limited, in order to provide personalised marketing communications using information obtained on our site.

When you submit a question to us, we may share your IP address with Freshworks, Inc, the provider of our customer support platform, to the extent required to help us process any customer support queries you might submit to us.

Annex 4 – Cookies

Elvie

Party setting cookies: Elvie

Types of cookies: Functional

When are the cookies set? When you first visit our Site

Description: We use a persistent cookie to enable you to store items in your shopping basket before you checkout. This cookie will remain on your device for 3 days.

We use a cookie that will remain on your device until you leave our Site which enables users to subscribe to our newsletters and to confirm consent.

We also set a cookie that will remain on your device until you leave our Site, which allows us to recognise you while you are browsing our Site so that you do not need to keep logging in. It also allows us to monitor and detect any fraudulent requests sent to our Site.

Amazon Pay

Party setting cookies: Amazon Payments

Types of cookies: Essential, functional and targeting

When are the cookies set? When you pay for products through the Site

Description: We set cookies that are required in order for Amazon Pay to process payments that you make through our Site. These cookies are required to store your payment details as you navigate between pages in the payment process.

Amazon Pay also uses cookies to store your information to provide you with a better, faster and safer experience when you make payments through the Site, as well as for advertising purposes.

Bazaarvoice

Party setting cookies: Bazaarvoice

Types of cookies: Functional and analytical.

When are the cookies set? When you first visit our Site

Description: Bazaarvoice is our review platform provider, and sets a cookie so that:

  1. your browser remembers your preference settings relating to reviews on our Site, e.g. filtering and sorting of content;

  2. your browser enables user-generated content submission;

  3. Bazaarvoice can receive anonymous analytics and measurement reporting

This cookie will remain on your device until you navigate away from our Site.

Paypal

Party setting cookies: Paypal

Types of cookies: Essential, functional and targeting

When are the cookies set? When you pay for products through the Site

Description: We set cookies that are required in order for Paypal and Braintree to process payments that you make through our Site. These cookies are required to store your payment details as you navigate between pages in the payment process.

Paypal also uses cookies to store your information to provide you with a better, faster and safer experience when you make payments through the Site, as well as for advertising purposes.

Facebook

Party setting cookies: Facebook

Types of cookies: Analytical / targeting

When are the cookies set? When you first visit our Site

Description: These cookies are associated with Facebook advertising. These cookies are used to help record your visit to our Site in order to determine appropriate advertisements to display to you on Facebook or a digital platform powered by Facebook Advertising. The Facebook conversion API uses first-party cookies (set to the domain of the retailer's page). Data stored inside this cookie includes:

  • Unique visitor IDs including your IP address and a unique Facebook User ID

  • Hashed email address and/or phone number of contact if they identified / logged in

  • Browser and click IDs for pages viewed

These cookies will remain on your device for a long time after you visit our Site, unless you delete it through the settings on your browser.

Google

Party setting cookies: Google Adwords, Google Analytics, Google Tag Manager, Google DoubleClick

Types of cookies: Analytical / performance and targeting

When are the cookies set? When you first visit our Site

Description: We set cookies when you visit our Site that are associated with Google Universal Analytics. They are used to calculate visitor, session and campaign data in order to generate reports and information about how the visitor uses the Site.

They are also used by third party analytics platforms, such as Hotjar, for similar purposes, as well as to support Google's advertising and remarketing platforms, including Adwords and Doubleclick.

These cookies will remain on your device for various periods – some will remain on your device for a long time unless you delete it through the settings in your browser.

Please visit https://tools.google.com/dlpage/gaoptout to see how you can opt out of receiving these cookies.

To control your advertising preferences or opt-out of certain Google advertising products, please visit the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Bing

Party setting cookies: Bing

Types of cookies: Targeting

When are the cookies set? When you first visit our Site

Description: We set cookies on your device that are associated with Microsoft Advertising. They are used to support our use of Microsoft's advertising and remarketing platforms.

For more information, please visit https://about.ads.microsoft.com/en-us/resources/policies/microsoft-advertising-privacy-policy

Klarna

Party setting cookies: Klarna Bank AB and/or Klarna’s subsidiary BillPay GmbH (for Swiss transactions only)

Types of cookies: Essential, functional and targeting

When are the cookies set? When you pay for products through the Site

Description: We set cookies that are required in order for Klarna and Billpay to process payments that you make through our Site. These cookies are required to store your payment details as you navigate between pages in the payment process.

Klarna and Billpay also uses cookies to store your information to provide you with a better, faster and safer experience when you make payments through the Site, as well as for marketing purposes.

Pinterest

Party setting cookies: Pinterest

Types of cookies: Analytics and targeting

When are the cookies set? When you first visit our Site

Description: We set a cookie on your device that are associated with Pinterest advertising and remarketing. They are used to support Pinterest's advertising and remarketing platform.

The cookie will remain on your device for a long time after you visit our Site, unless you delete it through the settings on your browser.

For more information, please visit https://help.pinterest.com/en/article/personalized-ads-on-pinterest

Outbrain

Party setting cookies: Outbrain

Types of cookies: Analytics and targeting

When are the cookies set? When you first visit our Site

Description: We set cookies and pixels to monitor the performance of our marketing campaigns and targeting functionalities through Outbrain.

These cookies will remain on your device for a long time after you visit our Site, unless you delete them through the settings on your browser.

Criteo

Party setting cookies: Criteo

Types of cookies: Targeting

When are the cookies set? When you first visit our Site

Description: We set cookies and pixels to monitor the performance of our marketing campaigns and targeting functionalities through Criteo.

These cookies will remain on your device for a long time after you visit our Site, unless you delete them through the settings on your browser.

YouTube

Party setting cookies: YouTube

Types of cookies: Analytics

When are the cookies set? When you watch an embedded video on the Site

Description: Youtube uses cookies to analyse traffic from embedded videos on our Site. Some of these cookies will remain on your device for a long time after you visit our Site, unless you delete them through the settings on your browser.

TikTok

Party setting cookies: TikTok

Types of cookies: Analytics and targeting

When are the cookies set? When you first visit our Site

Description: We set a cookie on your device that is associated with TikTok advertising and remarketing. They are used to support TikTok’s advertising and remarketing platform.

The cookie will remain on your device for a long time after you visit our Site, unless you delete it through the settings on your browser.

For more information, please visit https://www.tiktok.com/legal/cookie-policy

Typeform

Party setting cookies: Typeform

Types of cookies: Functional

When are the cookies set? When you follow troubleshooting flows in the product support section of the website.

Description: We set a cookie on your device that are associated with Typeform's online form building and online surveys. They are used to support Typeform's online form building and online surveys platform.

Ometria

Party setting cookies: Ometria

Types of cookies: Analytical / targeting

When are the cookies set? When you first visit our Site

Description: The Ometria JavaScript tracking library uses first-party cookies (set to the domain of the retailer's page). Data stored inside this cookie includes:

  • Unique visitor ID (random ID)

  • Email address of contact if they identified / logged in

  • Basket contents when navigating the site

  • Traffic source for this visit and first visit

  • Number of pages viewed

  • Time of first and last event

The data stored in the cookie is appended to the 'interaction tracking data', which is used to track active visitors on the Site. The cookie has a 1 year lifetime, which is renewed each time it is updated as a result of an interaction by the customer. 

Usersnap

Party setting cookies: Usersnap GmbH

Types of cookies: Analytical / targeting

When are the cookies set? When you first visit our Site

Description: Usersnap uses "cookies", which are text files placed on your computer, to help the solution to remember data already filled out and for handling your session. Some information about your use of the web application or website will be transmitted to and stored by Usersnap on servers in the European Union (EU).

Usersnap will store information about your IP address, geo-location, operating system, browser version, (browser) screen size, URL visited, your email, and name (in case you provided it).

These cookies will remain on your device for a long time after you visit our Site, unless you delete them through the settings on your browser.

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