Juvela Privacy Policy

 

Hero UK Ltd (trading as Juvela) (“Juvela”, “we”, “us”) is committed to safeguarding the personal information and privacy of our customers and visitors of our website www.juvela.co.uk (“Website”). We want you to feel confident about the privacy and security of your personal information when visiting our website, speaking to us on the phone and sending us forms in the post. This notice explains what information we collect about you, how we use it, how we store your data, what your rights are, and how to get in touch with us.

Juvela is the data controller for information processed as described under this notice. If you have any queries about our processing or how we handle your information, please let us know. Our contact details are in the “Contact Us” section.

Go to…

1. How and where Juvela collects data
2.What data does Juvela collect?
3.How Juvela uses your data
4.Our legal basis for collecting and processing your data
5.How long do we hold your data?
6.Do we share your data with anyone?
7. Your rights and choices
8.Marketing Preferences
9.Changes to our notice
10.Contact us

1. How and where Juvela collects data

We collect your data using one of these methods:

Juvela Cookies (website)

See our cookie policy for more information.

Juvela Customer Service (phone)

During the course of phone communications we may ask you for personal data (such as: name, surname, address, diet preferences) to update our records. We keep your details along with your telephone number in order to be able to deal with your enquiry more efficiently.

Juvela Sign up forms (post and in person)

We obtain personal data using sign-up paper forms. For example, a Starter Pack card may request your personal details as well as your marketing preferences. This information includes address (where to send it), your diet and diagnosis (which starter pack), email and telephone number (to update you about your starter pack and about Juvela products). You will have the option to provide this information without opting in to any/all marketing activity from Juvela. We require this information to determine if we should send a Starter Pack, and if so, which Starter Pack to send.

We also collect:

  • information you provide us on our website (www.juvela.co.uk) (“Website”) and on Juvela Club;
  • information you provide us at our events our roadshows;
  • information you provide when you voluntarily complete our surveys, provide feedback, and participate in customer focus groups;
  • correspondence you may have with us and any complaints you have brought to our attention so we can deal with your query or issue to the best of our ability;
  • information you post on our about us our social networking sites: Facebook, Instagram, Twitter

    2.What data does Juvela collect?

We send information about our products and recipes, notifications about events, news and marketing material. Depending on how you engage with us, we collect some or all of the following personal information about you:

Identification information:

Name – so we know who you are; Date of Birth – so we can verify your age for the purposes of consent; Gender – so we can send you targeting marketing communications

Contact Information:

Address – so we can send you information or products you have requested, or communicate with you about our products, services and other information you may find helpful; Email Address – so we can identify who you are and contact you with information you have requested or given us permission to send; Phone number – so we can contact you about any prescription changes

Health related information:

Coeliac Diagnosis – so we can send you our Starter Pack you have requested and other information you may be interested in; Diagnosis details (diet, hospital, year of diagnosis, method of diagnosis) – so we can verify your eligibility to receive a Starter Pack

Location information:

Approximate geographical location so we can contact you about events you may be interested in (if you have given us permission to do so), so we can locate stores near you, and so we can send you communications related to your approximate time zone

3.How Juvela uses your data

Juvela will endeavour to inform you of how we will use your personal data at every point of collection. Here is a list of ways we use your data:

  • To verify your identity when you sign up and sign into Juvela Club
  • To provide you with support for your queries when you contact us
  • To send you relevant information about Juvela products
  • To notify you about any items we have agreed to send you (such as Juvela Starter Pack)
  • To contact you to get a better understanding of your gluten-free requirements in order to improve our marketing to you
  • To notify you about events or news relating to gluten-free topics
  • To notify you about changes to particular products or services and delivery changes
  • To notify you about any policy changes
  • For our internal administrative purposes
  • To track your visits on the Juvela website in order to show you relevant ads on other websites (this is called remarketing)
  • To ensure the security of our services as well as for the purposes of preventing or detecting fraud

4.Our legal basis for collecting and processing your data

Juvela is committed to providing products to coeliacs and those on a gluten-free diet.

We collect and process data in the ways that you explicitly consent to.

We will also need to process your personal data for our legitimate interests where this processing is not overridden by your rights. Our legitimate interests are to improve our products and services, digital offerings, and for our administrative purposes.

We have not and will not obtain your information from third parties.

You do not have to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that we require will be marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information.

5.How long do we hold your data?

As Juvela is primarily a supplier of gluten-free foods for those with Coeliac disease, our data retention period reflects this.

For data owners with coeliac disease

We hold:

  • identification information for as long as you interact with us and then for a period of [2 years] after;
  • contact information for as long as you interact with us and then for a period of [2 years] after;
  • medical related information: for as long as you interact with us and then for a period of [2 years]
  • Location information: for as long as you interact with us and then for a period of [2 years]

After this period we will minimise this data to the minimum required to be able to send you important “service” notices such as prescription changes and delivery notices.

 

For data owners without coeliac disease

  • identification information for as long as you interact with us and then for a period of [2 years] after;
  • contact information for as long as you interact with us and then for a period of [2 years] after:
  • medical related information: for as long as you interact with us and then for a period of [2 years]
  • location information: for as long as you interact with us and then for a period of [2 years]

After this period, all data will be deleted unless required on legal grounds (for example in the event of a complaint).

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will stop processing that personal information and delete it.

If we have anonymised your personal information or aggregated your personal information in a way that you can no longer be identified from it, then we will continue to keep and use this anonymised information.

Please see our cookies policy for retention periods in relation to information we collect on your cookies.

6.Do we share your data with anyone?

Juvela is part of a larger group of companies called Hero group.  You can find out more about Hero at www.hero-group.ch. Hero Group is located outside of the EEA in Switzerland.  Switzerland does not have the same data protection laws as the United Kingdom and EEA however the European Commission has given a formal decision that Switzerland provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA so any transfer of your data to the Hero Group will be protected.

However, we do not share data with Hero group.

Third parties

We will only share your data with third parties where it is strictly necessary for the purpose of sending marketing, competitions or samples where you have given us permission to do so or where you have not withdrawn your consent. For example, if we are sending you a notification SMS, we will share your name and mobile phone number with our third party supplier who will send the SMS. If we are sending you a starter pack, we will share your name, email, telephone number and address details with the delivery company who will send you the Starter Pack.

Wherever possible, if we can reach you without sharing your personal details we will do so. For example, if we wish to inform you of a new product via Facebook, they will anonymise your data so that they do not hold your information that we provide.

We also share your data where necessary with:

  • Our software providers, application developers, and web-hosting companies;
  • Our professional service providers

Unusual circumstances

  • The Juvela customer database is part of the assets of the company. In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets where relevant;
  • If Juvela or substantially all of its assets are acquired by a third party, we may disclose personal data held about our customers, as these will be one of the transferred assets

Legal obligation

We will share or disclose your personal data, if we are under a duty to disclose or share it in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Juvela, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

7. Your rights and choices

Subject to certain circumstances, you have rights under data protection laws:

  • The right of access

Individuals have the right to access their personal data and supplementary information.

  • The right to rectification

The GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete.

  • The right to erasure

“The right to be forgotten” is a right for individuals to have personal data erased.

  • The right to restrict processing

Individuals have the right to request the restriction or suppression of their personal data.

  • The right to data portability

The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services, in certain circumstances.

  • The right to object

You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.

  • Rights in relation to profiling.

You have the right to object or restrict our use of your personal data for profiling (automated processing of personal data to evaluate certain things about an individual).

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We will handle any request to exercise your rights in accordance with applicable law.

8.Marketing Preferences

We contact you by Email, SMS, Phone or Post to provide you with information about our services and products that might be of interest to you. We will only contact you if you have provided us with your consent. If you would like to withdraw your consent, you can do this by contacting us using the details set out in the “Contact Us” section below.

 9.Changes to our notice

We will update this notice from time to time so we can tell you about our business developments and in response to changes in the law.

 10.Contact us

Hero UK Limited is the data controller for the processing of your personal data as described in this notice. We are registered in England and Wales under company number 06157827 and have our registered office at Unit 8, 19 De Havilland Drive, Liverpool, Merseyside, L24 8RN.

We are always happy to help with any requests or queries you have about your data and how you would like us to use it.  Please feel free to contact us using the details provided below:

  1. You can call us at 0800 783 1992
  2. You can email us at dataprotection@juvela.co.uk
  3. Write to us at: Data Protection Officer, Unit 8, 19 De Havilland Drive, Liverpool, Merseyside, L24 8RN

We will do our very best to answer any questions and resolve any complaint to your satisfaction. If, for whatever reason, you feel we do not meet the high standards we expect of ourselves, you have the right to complain to the UK Data Protection Supervisory Authority, the Information Commissioner’s Office (ICO) at www.ico.org.uk.