Privacy Policy

Atida Pure Privacy Policy December 2020

This is the Privacy Policy of Atida Pure B.V. (hereinafter Atida Pure and the Atida Privacy Policy).

Atida Pure takes the protection of your personal data very seriously. We process your personal data in accordance with applicable data protection regulations, including the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter the GDPR).

In this Privacy Policy we explain, among other things, which personal data we collect, for what purposes and on what legal basis, that depends on the various means of obtaining your personal data. We may update this Privacy Policy from time to time. We therefore advise you to consult our Privacy Policy regularly.

The privacy statement was last amended on December 17, 2020.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Atida Pure is an on-line supplements and health products retailer in the Netherlands with various digital marketing and sales channels. The website of Atida Pure can be found as www.atidapure.com (hereinafter the Website). Atida Pure is responsible for the processing of your personal data.

The responsible entity for all processing of personal data mentioned below is Atida Pure B.V., a company under Dutch law, residing at Fred Roeskestraat 115, 1076 EE Amsterdam (Chamber of Commerce: 78022568). Atida Pure is part of the OLP Group with its ultimate owner OLP EU S.a.r.l., a company under the laws of Grand Duchy of Luxembourg (société à responsabilité limitée), having its registered office address at 17a, rue des Bains, L-1212 Luxembourg, Grand Duchy of Luxembourg, registered with the trade register in Luxembourg (Registre de Commerce et des Sociétés) under number B236102 in Luxembourg.

2. WHAT PERSONAL DATA DOES ATIDA PURE COLLECT FOR WHICH PURPOSES?

2.1 THE SUBSCRIPTION PROGRAM

Purposes and Legal Bases of the Atida Pure Subscriptions Program

The Atida Pure Subscription Programme aims to improve your customer experience and increase satisfaction, including through personalized communication with information, offers and promotions that are tailored as much as possible to your preferences and interests. You will also see content on the Website that matches your interests and other preferences online and in your Account. You have access to your purchase history via your Account. The Atida Pure Subscription is voluntary and free of charge but we need it to process and manage your customised orders of health products.

The most important basis for processing your personal data in the context of the Atida Pure  Subscription  is the performance of the subscription agreement between us: the registration for and the implementation of the Atida Pure Subscription. To determine your preferences and interests, we use information that is obtained with cookies or similar techniques, with your consent. You always can withdraw your consent. We may also use your data for analysis and optimization purposes (at an aggregated level). The legal basis for this is a legitimate interest of Atida Pure to understand how customers use our services, in order to improve and optimize them.

Read more about the benefits of the Atida Pure Subscriptions  in the Atida Pure Terms and Conditions.

Register for the Atida Pure Subscription

Becoming a subscriber to the Atida Pure Subscription is easy and can be done by registering via the Website. For processing the orders and for our services, you will have to register your personal Atida Pure account (“the Account”). In the Account you upload certain (personal) data yourself.

Information associated with your Atida Pure Subscription

By analyzing your use of the various services of Atida Pure, we can adjust our services and communication to your wishes. Part of the Atida Pure Subscription is therefore that we link and add available information about you to your Atida Pure Subscription, including your interests, brand preferences, (online) purchases and information about your use of the Website and other services of Atida Pure.

Managing your Atida Pure Subscription: your Account 

You can set and manage your preferences and interests for the Atida Pure Subscription  yourself via your Atida Account environment on the Website. The following options can be found in your Atida Pure Account, amongst others:

• Cancel or Pause the entire Atida Pure Subscription;

• Set and change interests; 

• Unsubscribe from certain communications, if applicable.

We use your information to ensure that follow-up orders pursuant to your subscription can be processed. The legal basis for this processing is the proper execution of the agreement with you.

We also have access to your purchase history at Atida Pure. We use this information to assess how we can best help you and to give you personal advice. The legal basis for this is your request for this service and the provision of the subscription agreement we have with you. You will soon find your purchase history in your Account.

2.2 PAYMENTS

Atida Pure does not process any bank related personal data herself. Any and all payments done for Atida Pure products are handled by a third party payment services provider as indicated (hereinafter "the PSP"). For the payment process, you will be redirected to the PSP’s secured online payment environment where you will be invited to submit payment related data yourself, including personal data. The PSP  will process your personal data pertaining to your payment for Atida Pure products and services as a data controller in it’s own right. We refer you to the privacy statements of the respective PSPs that may change with time.  

The data can also be used to identify and detect fraud. The legal basis for this is a legitimate interest of Atida Pure and/or third parties to prevent fraud and other abuse of services. To prevent fraud, to check whether you can meet your payment obligations and to check all other relevant facts and factors important for duly entering and executing the (distant) agreement, Atida Pure may contact you randomly for audit questions, or Atida Pure may otherwise request you to provide additional information. The legal basis for this is the legitimate interest of Atida Pure and/or third parties to prevent fraud and other abuse of its services.

2.3 USE OF THE ATIDA PURE WEBSITES

Cookies

We need certain information to make the Websites work. This information consists of your IP address, the type of browser, the operating system you use, and the pages you visit on our Websites. The legal basis for this is the performance of our agreement with you, namely your visit to the Website and the legitimate interest of Atida Pure and/or third parties to secure the Website and services of Atida Pure and to detect and prevent fraud.

We use cookies and similar techniques to increase the user-friendliness of our Websites and to secure the Websites, to optimize your experience of our services, to make offers and personalize information for you, to recognize you on your next visit and to also inform you via other channels. The legal basis for the use of personal data obtained through cookies and similar techniques is your consent (with the exception of functional cookies and cookies with minor consequences for your privacy). In our Cookie Policy you can read more about which cookies are placed for which purposes and by which parties. 

You can always withdraw your consent via the link “Cookie information & settings” at the bottom of the Websites.

2.4 SOCIAL MEDIA

Atida Pure can be found on various social media, such as Facebook, LinkedIn and YouTube, Twitter, Instagram and Pinterest. If you follow Atida Pure via social media or communicate with or about Atida Pure via social media, we may view your public profile information. If you share information about Atida Pure via social media, your data may become visible via those social media. Atida Pure itself also follows social media channels and can thus may gain access to publicly available data on social media about you.

Atida Pure can keep track of how often a particular post from Atida Pure has been shared and “liked” via social media, in order to analyze its reach. Atida Pure can also keep track of whether and, if so, which messages about the Atida Pure are posted via social media channels of complaint sites. In that context, we process the data that is necessary so that we can optimize the content of our social media activities for our customers as much as possible, such as:

• Profile information of the relevant social medium;

• The viewed and posted content and messages related to Atida Pure; 

• Metadata stored in the platform.

The purpose of this processing is to analyze the reach of Atida Pure's social media activities and to improve its customer satisfaction. The basis of this processing is the legitimate interest of Atida Pure to improve its services and social media activities. This data can be added to your customer file if you have contact with our Customer Services via social media. The purpose of this processing is to handle your request. The basis for this processing is the performance of the agreement with you.

If you participate in any promotional action of Atida Pure via social media, we may ask your authorization to view and process personal data, such as:

• Name;

• Profile information of the relevant social medium;

• E-mail address (in the case of a digital prize);

• Address (in the case of a physical prize);

• Entry giveaway, which may include photo and / or video material.

We may use this information to contact you about the promotional action and to eventually send rewards to you (implementation of our agreement with you). In our Cookie Policy you can read more about social media cookies that we use.

2.5 PERSONALIZED HEALTH PRODUCTS 

Survey - Personalised offer 

On our website, we invite you to perform an online survey with questions about lifestyle, eating habits, allergies etc.  (“the Survey”) . The Survey is intended to help you with personalized advice for your Atida Pure Subscription. As part of the Survey, you will be asked to provide us with information about your health, lifestyle, including but not limited to your health goals, your diet, your lifestyle as well as your email address. It results in personal advice on a selection of products that match your personal situation and preferences.

You can order this personalised selection of supplements directly from our website  and have it delivered via our subscription programme. In placing your first order you will create an account with us and enter into the subscription agreement for periodic deliveries.   

In the future, you will be asked if you would like to receive the Atida Pure newsletter. You can always adjust this choice at a later time via the unsubscribe option at the bottom of the newsletter or in your Atida Account.

2.6 CUSTOMER SERVICE

If you contact or use the services of the Atida Pure Customer Service we collect the information necessary to handle your request, such as:

• Name and address details;

• E-mail address;

• Phone number;

• Content of correspondence;

• Call recording in case of telephone contact;

Depending on your request, our customer service employee will be able to access information necessary to process your request, for example whether you have an Account or if you have an Atida Pure Subscription agreement with us and/or the order status of your order.

We use this information to be able to respond to your complaint, request or question in order to execute our subscription agreement with you in an efficient and satisfactory way. Also, we store your questions in order to be able to help you more efficiently in the future and to analyze your customer satisfaction. This is based on the legitimate interest of Atida Pure to improve its services to you and other customers.

2.7 ATIDA PURE COMMUNICATION

In the future you will be able to sign up for the regular email newsletter from Atida Pure on the Website. The newsletter contains information about products, services and events of Atida Pure. The basis for this is consent.

As part of your Subscription Agreement,  you may receive newsletters from Atida Pure as well as newsletters that are tailored to your interests and preferences, based on your use of the services of Atida Pure and based on the preferences and interests you have specified. If applicable, you can indicate and change in your Account which type of newsletter you wish to receive, or you may indicate that you do not wish to receive mailings at all. The legal basis for this is our performance of the agreement with you. 

Mail

As a member of the Atida Pure Subscription you may receive mail with information and offers from Atida Pure. The legal basis for this is our performance of agreement. You can always unsubscribe from mail via your Account.

3. HOW LONG DO WE STORE YOUR DATA?

Atida Pure does not store personal data longer than necessary for the purposes for which they are collected or processed and in accordance with applicable legal terms. Atida Pure uses different retention periods, depending on the purpose and the category of data as mentioned below, unless we have to keep certain data longer on the basis of a legal obligation or a binding rule.

Atida Pure Subscription - Your Account 

The visible data stored in your Account will in principle be kept by us as long as you have the Atida Pure Subscription, with the exception of data that we must keep for longer according to a legal retention period.

Cookies

Atida Pure uses a maximum lifespan of six months for cookies and similar technologies. 

Newsletter

If you will register for the Atida Pure newsletter, Atida Pure will save your data in order to be able to send the newsletter until you indicate that you no longer wish to receive it. You can always unsubscribe with a link provided at the bottom of each message. When you receive a newsletter from Atida Pure, you can also unsubscribe from it in your Account.

Customer service

If you contact Atida Pure Customer Service, your personal data will be stored by us for a maximum of twelve (12) months after processing.

Customer satisfaction

If you participate in a customer satisfaction survey, the data you provide will be stored by us for a maximum of 24 months.

Information regarding fraud and theft

With regard to data regarding fraud and theft, Atida Pure applies a retention period of a maximum of five years, only insofar as this has been reported to the police.

If you have any questions about the retention period policy of Atida Pure, you can contact Atida Pure by sending an email to privacy@atidapure.com

4. TO WHOM DO WE PROVIDE YOUR DATA?

Atida Pure may use the services of third parties and group companies  to process your data in accordance with this privacy policy. These third parties act as processors for Atida Pure and Atida Pure ensures that these parties offer sufficient guarantees with regard to technical and organizational security measures. Third parties who act as processor for Atida Pure have concluded a processing agreement with Atida Pure which states, among other things, that they will only process your data on behalf of Atida Pure and on its instructions.

With these third party services we enhance our marketing, (cross-)selling, profiling and personal advice*, business analysis, automated decision making*, single sign-on on the Websites, the management of the Atida Pure Subscriptions, fulfillment and return management and customer services.

Your data can also be passed on to third parties, if and to the extent this is necessary for the proper performance of our Subscription agreement with you. In addition, we provide your data to other parties that we need in the context of our services, for example lawyers or bailiffs. Please note that we will only share the Survey,  including the health data that you provide in this respect, with third parties data processors governed by adequate data processing agreements and safeguards. 

Atida Pure can also offer its services to you in collaboration with other parties. For instance, to deliver your orders in accordance with the delivery method of your choice, and, to have them e-mail notifications to you about the status of such delivery. Also, your contact details and your delivery address will need to be provided to the appropriate delivery service. The delivery service is involved as an independently responsible party in the performance of the agreement with you. 

For more information about the processing of personal data by the relevant delivery service, you can consult the privacy statement on the website of the chosen delivery service. 

Other parties may also be involved in the performance of our agreement with you. These parties will act as an independent controller or as joint controller with Atida Pure. You will then be informed about this when you use such a service, such as for example the payment services of the PSPs (see above).

In other cases than the above mentioned and the activities that are marked with an *, Atida Pure will only process and provide information to third parties with your explicit consent or if it is obliged to do so on the basis of laws and regulations, or when Atida Pure is forced to do so as a result of a lawsuit and/or if it deems this necessary for the protection if its own interests and/or interests of the Atida Companies or (contracted) third parties.

5. DO WE TRANSFER YOUR DATA TO OTHER COUNTRIES?

Atida Pure may use the services of third parties to process your data in accordance with this privacy statement. In principal we will not transfer your data outside the European Economic Area. Should we do so, we will ensure an adequate protection level.

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

Atida Pure has taken appropriate technical and organizational measures to protect your personal data against loss or any form of improper processing. For example, we have taken encryption measures to prevent unauthorized third parties from accessing data.

Our customer data is stored in locations that are both physically and technically secure. It also logs who has had access to the user data. Only a limited group of employees has access to customer data on the basis of their job profile. The employees who have access to the data are trained and instructed in advance how to handle this data. They are also bound by rules of confidentiality. Several times a year, security checks are carried out by external specialists to guarantee full security of your personal data. Any points of interest that arise from this are immediately addressed and resolved.

7. WHAT HAPPENS IN THE EVENT OF TRANSFER OF THE COMPANY?

In the future, one or more parts or assets of Atida Pure may be transferred to another or a new sister, parent or subsidiary company of Atida Pure or third party. Or, Atida Pure may merge with such a party. In such cases, your personal data can also be transferred to this newly established Atida Company or third party. Atida Pure will always inform you in advance in such a case.

8. WHAT ARE YOUR RIGHTS?

Inspection and correction

If you want to know which personal data Atida Pure processes about you and for what purposes, you can contact us via privacy@atidapure.com. You can also request changes or corrections to your data. Atida Pure will respond to your request as soon as possible.

Objection

You can at any time object to the use of personal data for direct marketing and / or (further) receipt of (certain) marketing information by contacting us  via privacy@atidapure.com. The e-mails or other messages sent by Atida Pure also include an unsubscribe option. If you use this, you will no longer receive such messages. You cannot unsubscribe from necessary service messages.

You can also object to other processing operations that Atida Pure bases on the basis of legitimate interest. These are usually processing operations that are necessary in the context of good and safe business operations, in which Atida Pure has weighed its interest against your privacy interest. If you feel that your personal circumstances outweigh the legitimate interest of Atida Pure and / or a third party to process your data, you can object by sending an email to privacy@atidapure.com.

Removal

If you want Atida Pure to delete your personal data and / or your Account, you can request this by sending an email to privacy@atidapure.com or via your Account online. It is possible that some personal data will be stored by Atida Pure after the deletion request, for example if this is necessary for the processing of orders placed or if there is a legal obligation to keep the data.

Restriction of processing

If you have valid reasons to request a restriction of the processing (for example because you think the personal data that Atida Pure processes is not accurate, or you have objected to the processing of personal data by Atida Pure) please send an email to privacy@atidapure.com.

Data portability

If the processing of personal data by Atida Pure is based on your consent and is carried out via automated processes, you have the right to request that the relevant personal data that you have provided to Atida Pure be obtained in a structured, commonly used and machine-readable form. You can request this by sending an email to privacy@atidapure.com.

Withdraw consent

If a processing of your personal data is based on your (explicit) consent, you have the right to withdraw this consent at any time, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal, nor the lawfulness of processing of other personal data that was collected on another legal basis. You can withdraw your consent by sending an email to privacy@atidapure.com or, if applicable, via your Account.

Complaint

If you have a complaint about the use of personal data by Atida Pure, you have the right to submit a complaint to the Dutch Data Protection Authority.

Manage your data via your Account

You can also view, manage, change and delete your data yourself in your Account via the Website. In doing so, you can: 

• Change your personal details or supplement the same with - for example - your telephone number and date of birth;

• Change your delivery addresses;

• View your order history;

• Specify interests and preferences, where possible;

• Unsubscribe from the Atida Pure Subscription;

• Change your Atida Pure Subscription settings.

9. CONTACT

For questions or comments about this privacy statement, please contact our Data Protection Officer via privacy@atidapure.com.

Date of publication: 17 December 2020