9 March 2022
For the purpose of the data protection laws the data controller is Wellpet Belgium BVBA (registered in Belgium with company number BE0638908811) with its registered office at MC SQUARE – Leonardo da Vincilaan 19, 1831 Diegem – Belgium.
LEGAL BASIS FOR PROCESSING YOUR DATA
Data protection law in the European Union contains a number of « lawful bases » for processing personal data. These are really legal justifications which mean organisations like us are allowed to have your personal information in the first place. We have been careful to ensure we have a lawful basis for all processing of data we undertake. Our lawful bases include:
Legitimate interests – this is a technical term in data protection law which really means we have a good and fair reason to use your data and we do so in ways which does not hurt your interests and rights. We sometimes use your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will send you promotional communications about our service, subject to your legal rights to control whether we do so. We do analyse how users interact with our website so we can understand better what elements of the design are working well and which are not working so well. This allows to improve and develop the quality of the online experience we offer all our users.
Consent – in certain cases we may ask for your consent before using your information.
WHEN DO WE COLLECT DATA FROM YOU?
Please find below a list of situations in which we may collect data about you:
- When you create an account or profile with us.
- When you sign up online to receive electronic newsletters, blog posts, special offers and other materials.
- When you join one of our loyalty programs online
- When you enter competitions or quizzes we may hold.
- When you choose to complete any surveys we send you.
- When you comment on or review our products.
- When you participate in our user community or otherwise contribute content to the website, such as by commenting on a blog post.
- When you engage with us on social media.
- When you book any kind of appointment with us or book to attend an event
- When you contact us in some way – online chat, email, text message, telephone help line for any reason, compliments, feedback or a request.
- When you fill in any forms.
- When you’ve given a third party permission to share with us the information they hold about you.
WHAT DATA DO WE COLLECT AND WHY DO WE USE IT?
Depending on how you interact with us (online, on the phone, etc.), we may collect from you various types of information, which are described in more detail below. In some instances, we may combine one type of information with another type of information, and store them together in our records. In all cases, however, we strive to limit the amount of information we collect and store to that which is necessary for the lawful reason we have your information in the first place. We inform you wherever possible whether we need information requested or whether you have the choice not to provide it, but can still subscribe for our updates and offers etc. We may not be able to provide a service if you do not disclose the information requested.
1.Information you provide to us when you interact with us
– Account information: such as your name, customer number, login ID, screen name, password, and/or security question and answer, and other registration information. Certain login information, such as your customer number, may be generated by us and then sent to you. We only collect (or create for you) unique login information for those activities that require an account. Your unique login information, especially your password, should always be kept confidential and should never be shared with anyone else.
– Personal contact information: This includes any information that would allow us to personally contact you, such as your name, home or mailing address, phone number (home, mobile), or email address. In some cases, this could include information that you give us about someone else. We typically collect personal contact information in connection with a variety of activities, including account registration (e.g. online shopping and website community features, newsletter sign-up, etc.), customer service, contests and promotions, and customer feedback. If you create an account with us, some of your personal contact information may be stored under your account profile.
– Demographic information and preferences: This includes any information that describes demographic characteristics and preferences, such as age, gender, preferences, interests, date of birth, age or age range, with your consent information about your pet (e.g., type of pet, breed size, sterilized or not, age, etc. – these are only provided if you choose to do so), general geographic location (e.g., post code or city and state), favorite products, hobbies and interests, or lifestyle information. We typically collect demographic information in connection with a variety of activities, including account registration (e.g., online shopping, website community features, newsletter sign-up, etc.), contests and promotions, and customer surveys. If you create an account with us, you may be allowed to modify certain demographic information stored under your account profile. We use this information to send you promotional emails and communications (with your consent), to make personalised recommendations of products when you return to the website (with your consent), to advertise to you (with your consent) when you visit other websites and to better understand our customers so we can improve our products and our customer’s experience of our business.
– Your feedback: This includes information that you voluntarily share with us about your experience in using our products or services, including our pet food and our website. Examples include comments and suggestions, testimonials, or other feedback you send us about what you may have liked (or disliked) about your experience in using our products or services. We typically collect this information in the form of customer surveys, feedback forms, and email correspondence. We use your feedback to understand what our customers think of our products and the experience they have of us, to improve our products and the customer experience and – if you agree to – to discuss your feedback with you.
– User-generated content and posts: This refers to any content that you create and then share with us (and perhaps others) by uploading it to one of our websites, such as our Facebook fan pages or website. Examples include photos, videos, personal stories, or other similar media or content. We mostly collect customer-generated content in connection with contests and promotions, website community features, customer engagement, and third party social networking. Any other information you choose to make public on the website (e.g. information shared with other members of our user community).
– Information on allergies and intolerance of your pets: This includes information on your pet’s allergies or intolerance, as provided by you to us through our customer service. Examples may include intolerance regarding our products or a component of a product. We only use this information with your explicit consent to follow-up on allergies and intolerance you may encounter when using our products as the case may be and in developing and improving our products. It’s always your choice whether you share such details with us.
2. Automatically collected information
When you interact with us through the website, we use various technologies (including cookies, as further described below) to collect certain information (described below) about your visits to and use of the website. We use this information to understand your needs and preferences better so we can offer you a better experience online, to monitor and maintain our online infrastructure improve our website generally.
In accordance to the information provided in the banner or notice emerging in our website when you first visit our website, browsing and remaining on our wbesite will be understood as you are consenting to the use of the abovementioned cookies as set out in this Policy and the Cookies Policy
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others are used to remember you when you return to the website and will last for longer.
3 .Info we receive and collect from other sources
We may obtain information, including personal data, from third parties and sources other than our webite, such as our partners, advertisers. If we combine or associate information from other sources with personal data that we collect through the Service, we will treat the combined information as personal data in accordance with this Policy.
4. Social media and advertising partners
We work with social media platforms and digital advertising platforms to:
– Make it easier for you to log onto your account (for instance by using your Facebook account)
– Show you advertising for our products and the products of other companies in the Wellpet group on other websites and social media platforms. For instance, if you show an interest or buy a product on our website, we may advertise that or other products we think may be of interest and you may see them on other websites and on your Facebook or other social media feeds. To do this we will share information with our social medial and digital advertising partners about your age, gender and interests for instance so they can better understand what you are interested in.
We want to bring you offers and promotions that are most relevant to your interests at particular times, in emails (where we have your consent) and on the website when you visit. To help us form a better, overall understanding of you as a customer, we may combine your information gathered across various channels, for example your online and offline shopping history. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us. In doing this, we may put you into one or more categories of customer which we use to help build our promotional and marketing strategies, and that category will in part dictate the promotional communications and recommendations you receive from us.
WE ARE NOT RESPONSIBLE FOR THIRD PARTY SITES/FEATURES
Our Site may provide links to, or features from, other third party sites (such as third party social networks or retailers) that we do not own or control. If you click on such links or use such features, you do so at your own risk. We are not responsible for the content or practices of any third party site, application, or feature.
SAFETY OF OUR PRODUCTS
In the event you would experience allergies or intolerance when using our products, your requests or claims regarding safety of our products should be submitted by contacting:
Wellpet Belgium BVBA
MC SQUARE – Leonardo da Vincilaan 19, 1831 Diegem – Belgium.
The data you provide for safety reasons is your name, contact details, pet information and health data relating to your pet’s allergy or intolerance. The processing of this data is for safety of our products only, and based on your consent. This data is used only for this purpose, and in separate digital environments and channels from the general commercial and marketing purposes. We will process it to adapt our marketing messages to you only upon your prior consent.
We may also have to transmit information on the safety of our products to the competent health authorities, on an anonymous basis.
DO WE SHARE YOUR PERSONAL INFORMATION?
Wellpet is a company with products sold across the world. As a global business, we may share your personal information with Wellness Pet LLC company that owns Wellpet Belgium BVBA and trusted third parties based outside the country in which you live so that they may process that data on our behalf. We will never rent, trade or sell your personal information to third party companies for their own marketing use.
Affiliates and Wellness Pet LLC entities
We may share (or receive) information about you, including personal information, with our global headquarter in the USA, Wellness Pet LLC, which headquarter is 200 Ames Pond Drive, Tewksbury, MA 01876 USA.
Wellpet Belgium BVBA is in charge of leading our ecommerce, customer relations and marketing efforts for the Europe, Middle East and Africa region and this means they are also a joint controller of your personal data under European data protection law.
Pantheon is in charge of defining and administering of Wellness Pet LLC Group’s IT system, and providing technology infrastructure, including through their third party suppliers, which helps us for instance host the website and your information.
Third party vendors and providers
We sometimes share your personal data with trusted third parties. For example, to handle complaints, to help us personalise our offers, website, application development, hosting, maintenance, customer relationship management and promotional services to you and so on.
Where we use any of these providers:
– We provide only the information they need to perform their specific services.
– They may only use your data for the purposes we specify in our contract with them.
– We work closely with them to ensure that your privacy is respected and protected at all times.
– If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
For some suppliers, we and our group company need to transfer your information to locations outside the European Union, such as to the United States.
Legal disclosures (when necessary)
This is when we may need to share your information for law enforcement or other legal purposes. This type of sharing may be necessary in connection with a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter. Sharing your information for these reasons is not a regular event, but could arise from time to time. We will strive to limit the types and amount of information we may need to share for legal purposes to that which is reasonably necessary and will make sure that any transfers outside the European Union is made on the appropriate legal basis.
Business transfers (e.g., sale or acquisition of company)
To the extent allowed by the law, we may share (or receive) information about you, including personal contact information, in the event of an acquisition, merger, sale, corporate restructuring, bankruptcy, or other similar event that involves Wellpet Belgium BVBA or its parent or affiliated companies. If such an event occurs, we will take reasonable steps to require that your information be handled in accordance with this Policy, unless it is not practicable or permissible to do so and will make sure that any transfers outside the European Union is made on the appropriate legal basis.
Wellpet Belgium BVBA is headquartered in the United States, and we have operations, affiliates, entities, and service providers in Europe and throughout the world, including in the United States. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
Whenever we transfer your personal data out of the EEA, Switzerland or United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that these transfers are based on standard contractual clauses, in compliance with the model clauses validated by the European Commission or, for some transfers to the United States, under the Privacy Shield program, details of which you can find here: https://www.privacyshield.gov/welcome.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Wellpet knows how much data security matters to all our customers. So we take great care to treat your data and take all appropriate steps to protect it, and require the same of our suppliers who we share your data with.
We take measures to protect your information, depending on the sensitivity of the data and other considerations (such as how the information is collected and where it is stored). These measures may include (among other things) additional access restrictions, password requirements, and physical protections (e.g., secure data centers, etc.).
Measures you can take
Despite all of our efforts, no security safeguards or standards are guaranteed to provide 100% security. It is also important for you to play a role in keeping your information safe and secure. When signing up for an online account, please be sure to choose an account password that is hard for others to guess and never to reveal it to anyone else. If you use a shared or public computer, never choose to have your login ID or password remembered and make sure to log out of your account every time you leave the computer.
Please note, however, that these protections do not apply to any information you choose to share in public areas such as our website community features or other social areas. We pay particular attention to sensitive data, in particular, personal data, allergy or intolerance data, etc.
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Policy. The criteria used to determine such retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal or business obligation to which we are subject; or (iii) whether a longer retention period is required or permitted by law.
YOUR RIGHTS AND CHOICES
You have the legal right to request:
– Access to the personal data we hold about you.
– The correction of your personal data which is wrong.
– In some specific cases, the erasure of your personal data.
– That we stop using your data where our ‘lawful basis’ is consent by withdrawing your consent at any time, or to object to our use of your data where our ‘lawful basis’ is legitimate interests and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
– In specific cases, that we restrict our processing of your personal data;
– That we stop using your personal data for direct marketing.
– If your data is processed automatically based on your consent or the performance of a contract with you and, to obtain a copy of the personal data you provided us, in a commonly used format, to transmit it to another data controller.
You have the right to request a copy of any personal data we hold that relates to you. To ask for your information, please contact us in the Contact section, to ask for your information to be amended, please update your online account, or contact our Customer Services team.
If we choose not to action your request we will explain to you the reasons for our refusal.
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
INTERNATIONAL PRIVACY LAWS
This Policy represents our accepted privacy principles but does not supplement or replace existing national law. It complements the respective national data protection law. The respective national law supersedes in case where it requires deviations from this Policy or sets more stringent requirements. Likewise, the contents of this Policy shall apply if no corresponding national data protection law exists.
DISPUTE RESOLUTION / CONTACTING THE REGULATOR
If you have any complaints regarding our compliance with this Policy, please first contact us(Link to contact form). We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Policy.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. (see https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).
: MC Square – Leonardo de Vincilaan 19, 1831 Diegem – Belgium
We reserve the right to change the provisions of this Policy at any time. We will post changes directly on our website.