Privacy policy

Date of effectiveness 25 October 2021



This privacy policy (together with our terms of service and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting uk.klarify.me you are accepting and consenting to the practices described in this policy. 



WHO ARE WE? (OUR IDENTITY & CONTACT DETAILS) 


ALK e-com A/S
Bøge Allé 6
2970 Hørsholm
Denmark 

Email info-uk@klarify.me, (hereinafter: “klarify.me”)



Company Registration


Danish company register number (CVR No.): 39266881



SHOPIFY AND PAYMENT PROCESSING


Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services.


By visiting or using our store you acknowledge and accept not only this klarify.me Privacy Policy but also the Privacy Policy of Shopify, which is an independent third party, available here.


Your data is stored through Shopify’s data storage, databases and the general Shopify application in accordance with Shopify’s privacy policy.



Payment:


If you choose a direct payment gateway to complete your purchase, then Shopify will store your credit card data (and we will not) and Shopify will store and use your data in accordance with its privacy policy (link). Your purchase transaction data will be encrypted through the Payment Card Industry Data Security Standard (PCI-DSS) and is stored only as long as is necessary to complete your purchase transaction. After your purchase completes, your purchase transaction information is deleted.


All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.


PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. 


For more details, please see Shopify’s Terms of Service and Privacy Policy.



WHAT DATA WE PROCESS & WHY

Please note section iii below which applies when you activate your Home Allergy Test.



i. DATA PROCESSED BY US WHEN YOU BUY OUR PRODUCTS ONLINE


TYPE OF DATA: contact (including name, surname, email, mobile phone numbers, address), delivery, payment and purchase details


PURPOSE: to proceed with your order of product(s) and/or services and for billing purposes (which may include reminding you of any abandoned items in your shopping basket) Your data may be shared with third parties for the purpose of fulfilling your order (for example to ensure delivery to the correct address).


LEGAL BASIS: processing necessary for the contract for the sale of products and/or services


RETENTION PERIOD:we will determine an appropriate retention period for contact data, and in determining what is appropriate, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.   If you would like further information on our data retention periods, please contact: info-uk@klarify.me


SOURCE OF DATA: data will be collected from the information you provide to us when you make a purchase through our website


REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING:you are required to provide the data for the purpose of making a purchase through our website and without that data, the purchase will not be possible


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TYPE OF DATA: electronic contact details (including email) and type of products purchased


PURPOSE: direct marketing of our similar products and/or services (you may always opt-out)


LEGAL BASIS: processing necessary for our legitimate interests as described in the purpose


RETENTION PERIOD: up to 2 years from your last purchase, unless you opt-out/unsubscribe before


SOURCE OF DATA: the information you provide to us when you make a purchase through our website


REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING: you are not required to provide the data for this specific purpose, data is collected when you provide them for the purpose of making a purchase through our website, and you may at any time opt-out/unsubscribe from direct marketing communication


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TYPE OF DATA: technical data (including IP address)


PURPOSE: to analyse customers’ browsing patterns to enable us to operate, develop and improve our website


LEGAL BASIS: processing necessary for our legitimate interests as described in the purpose


RETENTION PERIOD: we will determine an appropriate retention period for technical data, and in determining what is appropriate,  we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. If you would like further information on our data retention periods, please contact: info-uk@klarify.me


SOURCE OF DATA: as you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns.  We collect this data by using cookies or similar technologies.  Please see the section on “Cookies” below    


REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING: you can set your browser to refuse all or some cookies.  However, if you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. Please see the section on “Cookies” below



ii. DATA PROCESSED BY US WHEN YOU CONTACT US


TYPE OF DATA: contact details (including postal address where you have requested samples from us) and content of your communication

PURPOSE: to resolve issues or to provide answers to your enquiries (as relevant) or where you have signed up to receive free sample(s) from us, we will use your contact details for the purpose of sending you the requested sample(s) and seeking feedback on the sample


LEGAL BASIS: processing necessary for our legitimate interests as described in the purpose


RETENTION PERIOD:as long as needed for the purpose (data will be subject to periodic reviews)


SOURCE OF DATA:data will be collected from you when you contact us or sign up to receive sample products from us


REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING:you are not required to provide the data, the data will be collected when you contact us or sign up to receive the sample(s) from us



iii. DATA PROCESSED BY US WHEN YOU ACTIVATE YOUR HOME ALLERGY TEST


TYPE OF DATA: contact (including name, surname, email, mobile phone numbers, address), technical data (including IP address), data relating to your health


PURPOSE: to analyse the blood sample submitted by you and report to you on the results. We may also anonymise data and results generated by our home allergy test and use these for internal analysis to improve our products and services.


LEGAL BASIS: (i) Processing necessary for the contract for services and our legitimate interest to improve our products. (ii) Express consent always in relation to health data (special category personal information).


RETENTION PERIOD: we will determine an appropriate retention period for the data, and in determining what is appropriate, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. If you would like further information on our data retention periods, please contact: info- uk@klarify.me


SOURCE OF DATA: data will be collected from you when you activate your test and from the analysis of the blood sample provided


REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING: you will not be able to get your results if you do not activate your test and create an account as we do not share results of tests through other means.



THIRD PARTIES: we will need to share your blood sample with a third party partner laboratory for analysis. Data is collected, processed and exchanged on both sides. In our partner laboratory your data is linked exclusively to the unique activation code for the Home Allergy Test, so data generated by the laboratory cannot be associated with any particular individual by them.



AUTOMATED DECISION-MAKING AND PROFILING

In order to provide you with high-quality products and services tailored to your needs and expectations, we may be using automatic tools and the types of tools we use are described in the section on “Cookies” below. However, you will not be subject to any decisions based solely on automated processing (including profiling), which would produce legal effects concerning you or would significantly affect you in a similar way. 



WHO WILL WE DISCLOSE YOUR PERSONAL DATA TO (RECIPIENTS OF PERSONAL DATA)


i. ALK’S EMPLOYEES & EXTERNAL PROCESSORS


The recipients of your personal data will be employees of entities belonging to ALK Group and external processors providing specific services and processing personal data on our behalf and only in accordance with our instructions. They will receive your personal data only on a need-to-know basis (mainly for the purposes of fulfilling orders to you), being subject to the obligation of confidentiality and after signing appropriate legal documents. The complete list of entities forming ALK Group is available here


We process your personal data in the UK and European Economic Area. Transfers between the two areas are permitted by virtue of: the UK GDPR’s adequacy regulations in respect of Europe; and the EU GDPR’s adequacy decision in respect of the UK. In the course of carrying out the activities referred to above, your data may also be transferred to processors in other countries, which may not have the same legal protections for your data as the UK or Europe. In such cases, we will take steps to ensure that your personal data is adequately protected in accordance with the applicable UK GDPR or EU GDPR legal requirements (whether that is the use of standard contractual clauses which have been approved for such purposes, binding corporate rules or other permitted transfer mechanisms).



ii. INDEPENDENT THIRD PARTIES


We may disclose your personal data to third parties (such as attorneys) when this would be necessary for the establishment, exercise or defence of legal claims or to public authorities, when required by the law, or, when needed, to independent third party auditors. 



THIRD-PARTY SERVICES


Third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies/notices. They are independent service providers and we will not share your personal data with them, instead, you will decide upon conducting a transaction or choosing a payment method whether you wish to use such services and provide your personal data subject to their privacy policies. We recommend that you check third party privacy policies so that you are clear on how your personal data may be processed.


We recommend that before conducting a transaction or choosing payment method, as relevant, you read their privacy policies/notices so you can understand the manner in which your personal data will be handled by these providers. 



COOKIES & SIMILAR TECHNOLOGIES


This site uses cookies and similar technologies. More information about what cookies are is available here and more information about EU legislation on cookies is available here.You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.


Where consent is needed for use of cookies and similar technologies, we obtain it through a consent banner when you visit the website.


Please note that this site does not respond to “Do Not Track” signals from internet browsers.


For more information on the cookies and similar technologies being used in this website, please see our cookie policy.


In addition to the cookies and similar technologies set out in our cookie policy, we use a technology service called Hotjar on this site to analyse customers’ browsing patterns to enable us to understand our users’ experience and improve our website. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (such as technical data (including IP address in anonymised form), geographic location (country), and language preference). Hotjar stores this information in a pseudonymised user profile. Neither Hotjar nor we will use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out of the creation of a user profile by Hotjar, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.



SECURITY


We implement appropriate technical and organisational measures to protect your personal data and to ensure such data is processed in accordance with applicable laws and standards. For the transmission of customer data, we use a secure transmission method (SSL) for the highest possible security standard.



CHILDREN


Our site is aimed at adults and we do not knowingly solicit or collect personal data or information from or about individuals under the age of 18.



WHAT ARE YOUR RIGHTS 


If you wish to exercise any of your rights, please contact us using our contact details provided at the beginning of this policy.


i. ACCESS AND RECTIFICATION


You may access your data, as well as have inaccurate data rectified.

You are entitled to obtain a copy of your data, which will be provided to you in such a way as to respect the rights and privacy of other persons.


You are also entitled to ask us to provide you with any relevant details concerning the processing of your personal data.



ii. DATA PORTABILITY


You are entitled to receive data you have provided to us in a portable format (structured, commonly used and machine-readable format) and to have such data transferred to you or, when feasible, directly to another entity or person you expressly choose.


Please note, that the data will be provided to you in such a way as to respect the rights and privacy of other persons.



iii. RIGHT TO OBJECT


You may object to the processing of your personal data which is processed based on our legitimate interests and there is something particular about your situation which makes you want to object to processing on the grounds that you believe it impacts on your fundamental rights and freedoms.  You also have the right to object when such data is processed for direct marketing purposes without giving any reasons.



iv. RIGHT TO WITHDRAW CONSENT


If you have given consent to use your personal data to us, you have the right to withdraw your consent at any time. For this purpose, you may email us at data.protection@alk.net. or please contact us using our contact details set out above.


Your withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.



v. ERASURE (‘RIGHT TO BE FORGOTTEN’)


You may ask for your personal data to be deleted and no longer processed at any time. However, we may not always be able to comply with your request for erasure for specific legal reasons (e.g. if some data still needs to be stored for tax reasons) in which case, we will notify you of these reasons and give you an indication of when that data is likely to be deleted.  Note that the right to erasure does not apply to anonymous statistical data (which will not contain any personal data).



vi. RESTRICTION OF PROCESSING


Instead of erasure, you may ask to have your data restricted. Further processing of restricted data may take place only with your consent or for reasons expressly stipulated by applicable law(s).


If the restriction would not be possible, because of justified legal reasons, you will be expressly informed about such reasons before the restriction is lifted.



vii. COMPLAINTS


If you wish to complain, please contact us using our contact details or send an email at data.protection@alk.net.


viii. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

If you believe that the processing of your personal data infringes EU or UK law, you are entitled to lodge complaints with a supervisory authority, in the particular EU Member State or other country of your habitual residence, place of work or place of the alleged infringement.



CHANGES TO THIS NOTICE


This privacy policy may be updated from time to time. If we make material changes, we will notify you by means of a prominent notice on the site prior to the change becoming effective, and where appropriate, send a direct communication to you about the change.

 

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