Privacy policy

Privacy Policy - First Class Nourishment LTD.

Last Updated: 12th March 2022

1. Who we are and the purpose of this Privacy Policy

2. Data we may collect about you

3. How we collect your personal data

4. How we use your personal data

5. To whom and when may we share your data

6. International transfers of your personal data

7. How we keep your personal data secure

8. How long we retain your personal data

9. Exercising your legal rights

10. Cookies and other technologies

11. Controlling the processing of your personal data

12. Updates to this Privacy Policy & informing us of changes to your personal data

13. Complaints and how to contact us

 

1. Who we are and the purpose of this Privacy Policy

ThinkPharm Health is a food supplement business which is part of First Class Nourishment LTD ("We", "Our", "Us"). The purpose of First Class Nourishment LTD. is to improve the health and nutrition of its customers.

The privacy policy below explain how and why First Class Nourishment LTD. collects, uses and protects your personal data when you visit or purchase a product from our website: www.thinkpharmhealth.com. Your trust is important to us and we are committed to protecting your personal data.

First Class Nourishment LTD. is only responsible for the privacy practices of the websites that we own and operate. Our websites may include links to third party websites for your convenience. If you choose to access such third party websites, we recommend you check their privacy policies so that you understand their privacy practices.

Additional privacy notices and/or consent forms will, if necessary, be communicated to you relating to specific situations where First Class Nourishment LTD. may process your personal data.

Full name and contact details of the data controller:

Our name: First Class Nourishment LTD.

Registered office: First Class Nourishment LTD., 124 City Road, London EC1V 2NJ

If you have any concerns or questions about our use of your personal data, or would like to exercise any of your privacy rights or choices, please contact us at info@firstclassnourishment.com.

2. Data we may collect about you

First Class Nourishment LTD. collects personal data about visitors/users of the website and about any customers making a purchase through the website. The type of personal data we collect depends on the nature of our relationship with you, how we interact with you and the requirements of applicable laws. It may include:

  • Order information and account registration information: information regarding your order through the website, including your name, billing address, shipping address, payment information (including debit and credit card numbers), e-mail address, phone number and order status.
  • Your marketing preferences: your name, e-mail address, whether you wish to be contacted with marketing communication and your communication preferences.
  • Interaction data: your questions about and feedback on our business, products and services (including your responses to surveys/forms you choose to complete).
  • Technical data: information from your use of our digital platforms, including details about the devices used (E.G. your IP address, type of browser, operating system, mobile network data, time zone), access times, URLs clicked on, search terms used, pages/products viewed (including the page you visited before our website).
  • User behaviour data/analytics: information about how you use our website, including move maps (where a user's cursor moves whilst navigating the website), scroll maps (how far down a page a user scrolls) and click maps (where users click or tap). 

3. How we collect your personal data

We collect personal data about you when you interact with us directly on the website. For example, when you visit and interact with our website, make a purchase or attempt to buy through the website, contact us to give feedback, make enquiries, complaints or request information and choose to complete forms or surveys.

In addition, we collect certain information about the use of our websites and mobile applications by automated means, such as cookies and other similar technologies.

We may combine information that we have about you from multiple sources.

4. How we use your personal data

We use your personal information in accordance with data protection legislation, this Privacy Policy and primarily for the following purposes:

  • Fulfilling your online orders: We use your order information to fulfil any orders placed through the website, including processing payment information, arranging for shipping and providing you with invoices and order confirmations.
  • Providing you with information or advertising in relation to our products and services: When in line with the preferences you have shared with us, we may use your personal data to provide you with information or advertising relating to our business, products and services that is tailored to suit what we think you will find interesting and relevant (profiling). You can choose what information you receive and how you receive it.
  • Conducting our business operations: evaluating and improving our business, products and service. Responding to questions and feedback. Contacting you for participating in surveys and market research (with your consent where legally required). Communicating product safety information and responding to safety and product quality concerns (including product recalls). Evaluating and improving the use of our website and our communication strategies (for example, by generating analytics about how our customers browse and interact with the website, and to assess the success of our marketing and advertising campaigns).
  • Detect potential fraud: We use your personal data to screen our orders for the potential risk of fraud.
  • Complying with applicable laws, regulations, industry codes and guidance: including responding to adverse events, product side effects, product safety, complaints, quality concerns and medicines information enquiries. Investigating illegal activity/misconduct, breaches of our company policies or terms and conditions governing the use of our products, services and/or digital platform. Enforcing our legal rights or in connection with litigation.
  • Complying with requests from regulators, data protection supervisory bodies, government investigations, courts and law enforcement authorities.

We may aggregate and/or de-identify any data we collect such that the information no longer identifies you as a specific individual. We may process such information for our own legitimate business purposes, without restriction (including for analysing engagement trends, for other statistical analysis and for business planning).

On what legal basis do we process your personal data?

Our legal basis for processing your personal data for the purposes described above will depend on the personal data concerned and the specific context in which we collect it.

  • In some cases, we may seek your consent to collect and process your personal data for certain purposes. If we process your personal data on the basis of your consent, you can withdraw your consent at any time by contacting us as set out in the "How to contact us" section below.
  • Contract administration. Processing is necessary to perform our obligations under a contract with you.
  • Legal obligations. Processing is necessary to comply with our legal and regulatory obligations.
  • Legitimate interests. Processing is necessary for our legitimate interests, where these do not prejudice or harm your rights and freedoms. For example:
    • to operate, evaluate and improve First Class Nourishment LTD.'s business and promote innovations in the research and development of new products.
    • to obtain information that may have an impact on the benefit/risk assessment of products and on the safety of those taking the products.
    • to benefit from services offered by third parties.
    • to sell or reorganise all or any part of our business.
    • to prevent fraud, illegal activity, misuse of our products/services and the security of our IT systems and network.

5. To whom and when may we share your personal data

We may share your personal data with the following categories of recipients for the purposes set out in this Privacy Policy or as notified to you when we collect your personal data:

  • Other First Class Nourishment LTD. companies (there are no others at present)
  • Our third party service providers. Examples include: our e-commerce platform provider Shopify Inc., that powers our online store (you can read more about how Shopify uses your personal data here: https://www.shopify.com/legal/privacy), our order fulfilment and packing provider, Fulfilment Matters Ltd (you can read more about how Fulfilment Matters uses your personal data here: https://fulfilmentmatters.co.uk/privacy-policy/), providers of product quality services, pharmacovigilance service providers, product recall service providers, call centres, market research programme providers, technology suppliers, data storage and analytics (analytics is partly conducted by Hotjar Ltd., whose privacy policy you can see by clicking here.) suppliers, payment providers, shipping and fulfilment providers (EG. Royal Mail), auditors, lawyers and insurers. More information on our analytics providers can also be found in the section below "Controlling the processing of your personal data".
  • Worldwide regulatory bodies, data protection supervisory authorities, law enforcement bodies, government authorities, courts, tribunals, arbitrators or other judicial committees.
  • Third parties in connection with the sale, transfer or reorganisation of our business or assets (or any similar business changes).
  • Any other person with your consent.

6. International transfers of your personal data

Occasionally, First Class Nourishment LTD. may transfer your personal data to our companies or our third party service providers in accordance with applicable data protection laws and for the purposes described in this Privacy Policy or as notified to you when we collect your personal data. Some of these entities and their databases may be based outside the EEA or UK in countries that do not offer and equivalent level of protection for personal data as the laws of your home country. Specifically, we may transfer personal data from the EEA or UK:

  • Countries that the European Commission have deemed to adequately safeguard personal data by issuing an adequacy decision; Or
  • Third countries where the European Commission has not issued an adequacy decision where: (A) the recipient has entered into the EU standard data protection contractual clauses; (B) the recipient is certified under the EU-US Privacy Shield; (C) the recipient has regulator approved Binding Corporate Rules; (D) you have given your sonsent to the transfer; or (E) as otherwise permitted by EU law.

7. How we keep your personal data secure

First Class Nourishment LTD. maintains safeguards to protect your personal data from accidental, unlawful or unathorised access, loss, alteration, disclosure or use. We limit access to your personal data on a need-to-know basis and take measures such as data encryption and pseudonymisation wherever possible. Due to the potential for data breaches we cannot guarantee that the measures we have put in place will ensure the security of your personal data. We have put procedures in place to deal with any suspected personal data breaches. We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How long we retain your personal data

First Class Nourishment LTD. has a records retention policy that specifies how long we will keep your personal data. In general, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tex, accounting or reporting requirements. We may retain your personal data for a longer period in the even of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

In determining the appropriate personal data retention periods, we consider: (1) the amount, nature and sensitivity of the personal data, (2) the potential risk of harm from unauthorised use or disclosure of your personal data, (3) the purposes for which we process your personal data and whether we can fulfil those pruposes through other means, (4) applicable legal, regulatory, tax, accounting or other requirements.

9. Exercising your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • To request to have access to your personal data, known as a "subject access request". This enables you to receive a copy of the personal data First Class Nourishment LTD. holds about you and to check we are lawfully processing it.
  • To request the correction of your personal data. This enables any incomplete or inaccurate data we hold about you to be corrected, though we may need to verify the accuracy of the new data you provide to us.
  • To request deletion of your personal data. You have the right to ask us to delete your personal data where there is no good reason for us continuing to process it, or where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request of deletion for specific legal reasons which will be notified to you at the time of request (if applicable).
  • To object to the processing of your personal data where First Class Nourishment LTD. is relying on a legitimate interest (or those of a third party) and you feel that our processing of your personal data impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • To restrict the processing of your personal data where: (A) you want us to establish the data's accuracy, (B) our use of the data is unlawful but you do not want us to erase it, (C) you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, and/or (D) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • To request the transfer of your personal data to a third party in a structured, commonly used and machine-readable format. Note that this right only applies to automated information.
  • To withdraw your consent to the processing of your personal data in circumstances where First Class Nourishment LTD. is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before your consent was withdrawn. If you withdraw your consent we may not be able to provide certain products or services to you and we will advise you if this is the case at the time you withdraw your consent.
  • To make a complaint at any time about our processing of your personal data. We would appreciate the opportunity to resolve your concerns in the first instance. You can also make a complaint to the Information Commissioner's office at ico.org.uk.

You can exercise these rights by contacting us as set out in the "How to contact us" section below and we will respond in accordance with applicable data protection laws. We may need to request specific information from you to help us confirm your identity and discuss your request. There may be circumstances where we are legally entitled to continue processing your personal data or refuse your request.

Note that you are able to set some controls on how First Class Nourishment LTD. processes your personal data without having to exercise any of the rights described in this Privacy Policy. Please see the "Controlling the processing of your personal data" section below.

10. Cookies and other technologies

First Class Nourishment LTD.'s websites, applications, e-mails and advertisements may use cookies and other technologies (such as device identifiers) to automatically collect certain information to help us understand: (1) how our digital platforms are being used, (2) to improve user experience, (3) to measure the effectiveness of our advertisements and services. We generally do not treat information collected by cookies and other technologies as personal data, unless we are required to do so under local law.

When you visit third party websites or mobile services, you may be provided with advertisements for First Class Nourishment LTD.'s products and services based on your online user behaviours. First Class Nourishment LTD.'s advertising network partners may also use cookies on First Class Nourishment LTD.'s websites and on other thirdparty websites to collect information about your online activities in order to provide you with online advertisements that are based on your interests. This is known as online behavioural advertising.

For more information about how and why we use cookies, please see our Cookie Policy. To learn about how to prevent information being collected automatically, including how to opt out of online behavioural advertising, please see the "Controlling the processing of your personal data" section below.

11. Controlling the processing of your personal data

You are able to set certain controls on how we process your personal data without having to exercise any of the rights described in this Privacy Policy.

  • Manage your account settings

If you do not wish to receive marketing e-mails from us, you can opt out by clicking on the "unsubscribe" link you will find at the bottom of our e-mails. Where you have registered for an account with First Class Nourishment LTD., you can manage your e-mail preferences via your account settings.

  • Manage your cookies and other preferences

A number of web browsers allow you to manage your preferences. You can refuse cookies, delete certain cookies and you may be able to manage other tracking technologies in a similar way. If you do choose to refuse or delete cookies, please note that not all elements of First Class Nourishment LTD.'s digital platforms may function as intended and this may have an impact on your experience.

  • Opt out of Online Behavioural Advertising

When a First Class Nourishment LTD. online behavioural advertisement is delivered to you, you will see an "Ad Choices" icon or link. Clicking on the icon or link will take you through to a website where you can manage or opt out of your browsing history data being used to deliver online behavioural advertising. On an iOS mobile device, you may have a "Limit Ad Tracking" setting oand on an Android device, you may have a "Opt out of Interest-Based Ads" setting - these allow you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

Opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that you will no longer be shown ads that have been tailored to your interests. You may still see advertisements from First Class Nourishment LTD. that are based on other information (E.G. based on the content of the page being viewed rather than your prior web-browsing activity). In some cases, data may still be collected about your browsing activity by these third-party advertisers, but they will not use this data to deliver advertisemennts that are based on your past online browsing behaviour.

To learn more about the choices that advertisers provide and how information about online activities is collected and used, you can visit any of the following:

  • Network Advertising Initiative (https://optout.networkadvertising.org/?c=1)
  • Digital Advertising Alliance (https://youradchoices.com/)
  • European Digital Advertising Alliance (https://youronlinechoices.eu/)

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the following common links:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

12. Updates to this Privacy Policy & informing us of changes to your personal data

We may update this Privacy Policy occasionally in response to changing legal, technical or business developments or in order to reflect, for example, changes to our practices or for other operational reasons. When we update our Privacy Policy we will take measures to inform you which are in proportion with the significance of the changes we make.

Please keep us informed if your personal data changes whilst you are still receiving products and services from us. It is important that the personal data we hold about you is current and accurate.

13. Complaints and how to contacts us

Got a concern? We'd love to resolve it.

If you have any questions regarding this Privacy Policy or would like to exercise any of your data protection rights, please contact us at info@firstclassnourishment.com.