Privacy policy

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We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

This website is operated by Symprove B.V., a company incorporated in the Netherlands with KVK number 87225522 and whose registered office is at Locatellikade 1, 1076 AZ Amsterdam.

We collect, use and are responsible for certain personal information about you. When we do so, if you are located in the European Economic Area (EEA),  we are regulated under the EU General Data Protection Regulation (EU GDPR) and other local EU laws. We are responsible as ‘controller’ of your personal information for the purposes of those laws. If you are located in the UK we are also regulated under UK data protection laws.

Our website

This privacy policy relates to your use of our website, http://www.symprove.eu/, only (including purchases you may make via our website).
Throughout our website we may link to other websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products via our website and complete customer surveys or quizzes or participate in competitions via our website.

We collect this personal information from you either directly, such as when you register with us, contact us, enter competitions or purchase products via our website or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).

The personal information we collect about you depends on the particular activities carried out through our website. This information includes:

• Identity Data: such as your name, title and date of birth
• Contact Data: such as your billing address, delivery address, email address and telephone number
• Financial Data: such as your bank account and payment card details
• Transaction Data: such as your purchase history and information about the products we provide to you
• Profile Data: such as your username and login details and details of any feedback or other information you give us by phone, email, post or via social media e.g. your reasons for using our products
• Technical Data: such as (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
• Communications Data: such as your communication preferences and your preferences in receiving marketing from us and our third parties 

We also collect, use and share aggregated data such as statistical data for various purposes. Aggregated data could be derived from your personal information but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also collect, store and use special categories of personal information. Special categories of personal information are categories of information that are considered to be particularly sensitive.

This information includes Health Data that you may voluntarily provide in response to a survey or quiz on our website.

We will only process special categories of personal information if an additional special category processing condition applies (see ‘How and why we process your personal information’ below).

How and why we process your personal information

When we use your personal information, we are required to have a legal basis for doing so. There are various legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• consent: where you have given us informed and explicit consent for us to process your personal information for a specific purpose.
• contract: where our use of your personal information is necessary for a contract we have with you or because you have asked us to take specific steps before entering into a contract, for example to fulfil an order you have made through our website
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations) e.g. for business accounting and tax purposes
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides the legitimate interests)

When we use your special category personal information, as well as a legal basis, we are also required to make sure that a special category processing condition applies.

Any special category data we collect about you we collect on a voluntary basis and we rely on your informed and explicit consent to collect and process this information. You are never required to provide us with special category data.

Where we are relying on consent to process your personal information you also have the right to withdraw your consent at any time by contacting us (for further information see ‘Your rights’ below).

Our surveys and quizzes

Any personal information you may provide in response to a survey or quiz on our website is entirely voluntary.

Some surveys or quizzes will collect information on an anonymous basis. Other surveys or quizzes may collect personal information from you, that will enable us to identify you. We will make this clear within the survey or quiz. 

Where necessary, we will also ask you to confirm that you consent to us collecting your personal information within the survey or quiz. Where we are relying on consent to collect and process your personal information you have the right to withdraw your consent at any time by contacting us (for further information see ‘Your rights’ below). 

Within the survey or quiz we will also explain the purpose for which we are collecting personal data. This will vary from survey to survey, but is likely to be to give us insight into customer experiences and how customers have found using our products. 

We use Typeform, our third party processor, to assist with creating and making surveys available to you. We have entered into a data processing agreement with Typeform to ensure the same level of security and confidentiality of your data. We remain responsible for these processing operations.

Call recording

We may record certain telephone calls that we have with you. We will notify you before call recording occurs. We record calls because it is in our legitimate interests to do so, for example for training and record keeping purposes and also to ensure that you receive quality service from us. Call recordings also help us to investigate and resolve any complaints.

You can object to a call being recorded at any time, by not proceeding with the recorded call and contacting us via an alternative route instead. You can also exercise your right of erasure at any time after a call recording has been created (see the “Your rights” section at the end of this policy).

All call recordings will be stored securely, with access limited to only those personnel who require access in relation to their job role. The length of time that we retain calls depends on the nature of the call and the purposes of the recording.

Our other processing activities

The table below explains what else we use your personal information for and why, as well as what our legitimate interests are where we are relying on our legitimate interests as the legal basis to process your personal information:

What we use your personal information for (the purpose)	Type of data	Legal basis
Create and manage your account with us, verify your identify or register you as a new customer	Identity Data Contact Data Profile Data	Performance of a contract with you
To process and deliver your order including: ●       Manage payments, fees and charges ●       Collect and recover money owed to us	Identity Data Contact Data Financial Data Transaction Data Profile Data Communications Data	●       Performance of a contract with you ●       Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: ●       Notifying you about changes to our terms or privacy policy ●       Asking you to leave a review or take a survey ●       To enable you to partake in a prize draw or competition	Identity Data Contact Data Profile Data Communications Data	●       Performance of a contract with you ●       Necessary to comply with a legal obligation ●       Necessary for our legitimate interests (to keep our records updated, study how customers use our products and promote generate interest in our products)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Data Contact Data Technical Data	●       Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) ●       Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Data Contact Data Profile Data Communications Data Technical Data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products, marketing, customer relationships and experiences	Technical Data Profile Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) OR ●       Consent, where we rely on your opt-in consent to deploy non-essential website cookies to collect analytics data
To make suggestions and recommendations to you about products that may be of interest to you	Identity Data Contact Data Technical Data Profile Data Communications Data	●       Necessary for our legitimate interests (to develop our products and grow our business) OR ●       Consent, where we rely on your opt-in consent to deploy non-essential website cookies or send you marketing communications

Who we share your personal information with

We routinely share your personal information with our external service providers.  These service providers include companies who provide us with accounting services, software tools, marketing services, payment services, courier and delivery services, email and website hosting and messaging tools for example WhatsApp. We only allow our service providers to handle your personal information if we are satisfied they take appropriate technical and organisational measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.  
We may share your personal information with any member of our company group which means our subsidiaries, our holding company and its subsidiaries.
We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
We will share personal information with law enforcement or other authorities if required by applicable law.

Transfer of your information out of the UK and EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal information to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal information.

For example, we will transfer your personal information to our service providers located outside the UK/EEA in the United States of America.

When we transfer your personal information to a country outside the UK/EEA we will ensure that the transfer complies with data protection laws by following one of the below steps:

• confirming that the recipient is located in a country which has been recognised as having an adequate level of protection for personal information by the UK or the European Commission, as applicable
• putting in place appropriate safeguards (such as approved standard contractual clauses), so that you have enforceable rights and effective legal remedies, or
• confirming that a specific exception applies under relevant data protection law

For further information about international transfers and the safeguards we employ, please contact us (see ‘How to contact us’ below).

Consequences of not providing your personal information

You are not obligated to provide your personal information to us. However, as some of this information will be required for us to provide our products to you, we will not be able to offer some, or all, of our products without it.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website.
For further information on cookies please see our cookie policy.

Marketing

We would like to send you information about our products, competitions and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone or text message (SMS).

If we are relying on our legitimate interests to send marketing  to you because you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about products similar to those which were the subject of a previous sale to you. We will only contact you for a period of up to three years after your most recent purchase.

We will ask whether you would like us to send you marketing messages when you tick the relevant boxes when you complete our online order form for the first time.  You can also sign up to receive marketing messages from us via our website.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

• contacting us using the contact details set out below
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

For service support or assistance, text HELP to Symprove or email support@symprove.eu.

We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honouring requests made in such messages.

For more information on your rights in relation to marketing, see ‘Your rights’ below.

Your rights

Under the UK GDPR and EU GDPR you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information
  
• access to your personal information and to certain other supplementary information that this privacy policy is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances

Where we are relying on consent to process your personal information you also have the right to withdraw your consent at any time by contacting us (see ‘How to contact us’ below). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services or functionality to you. We will advise you if this is the case at the time you withdraw your consent.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights or if you are located in the EEA, the guidance provided by your local supervisory authority.

If you would like to exercise any of those rights, please:

• email, call or write to us
• let us have enough information to identify you (g. account number, username, registration details). Please note that in certain cases if there is no other option we may request more information, for example a copy of your license or passport (shield your photo and citizen service number).
• specify the type of request and let us know the information to which your request relates including any account or reference numbers, if you have them

We will respond (in substance) to your request within four weeks. In special circumstances, this may take longer, up to a maximum of three months. We will then let you know within one month why that is the case.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any (suspected) data security breach. We will notify you and any applicable regulator of a (suspected) data security breach where we are legally required to do so.

Retention of personal information

We only retain your personal information for as long as is necessary. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
As an indication, we will keep your personal information whilst you are registered with us as a customer. Thereafter, we will keep your personal information for as long as is necessary to:

• respond to any questions, complaints or claims made by you or on your behalf for a maximum of one year after the question, complaint or claim has been definitively dealt with after which time it will be destroyed
• keep records required by law (e.g. we keep tax related data for a period of seven years) after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such personal information until you notify us otherwise and/or withdraw your consent.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

You also have the right to lodge a complaint with the ICO or any relevant European data protection supervisory authority.

The ICO can be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.

The supervisory authority in the Netherlands is the Dutch Data Protection Authority ('Autoriteit Persoonsgegevens'), which may be contacted at https://klachten.autoriteitpersoonsgegevens.nl/ or telephone: (0)708888500.

How to contact us

Please contact us if you have any questions about this privacy policy or the information, we hold about you.

If you wish to contact us, please send an email to privacy@symprove.com, write to Locatellikade 1, 1076 AZ Amsterdam or call (0)31852251903.

Policies and Procedures

We have the following policies available for public access:

• Subject Access Request Form
• Subject Access Request Procedure
• Data Retention Erasure Policy

If you would like a copy of any of the above policies, please contact us at privacy@symprove.com.

Changes to this privacy policy

This privacy policy was last updated on 23 September 2024.

We keep our privacy policy under regular review to make sure it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes on our website. We may also take reasonable steps to notify you if such changes affect how your personal information is processed

Cookie Policy

This cookie policy ("Policy") describes what cookies are and how they're being used by the symprove.eu website ("Website" or "Service") and any of its related products and services (collectively, "Services"). This Policy is a legally binding agreement between you ("User", "you" or "your") and this Website operator ("Operator", "we", "us" or "our"). You should read this Policy so you can understand the types of cookies we use, the data we collect using cookies and how that data is used. It also describes the choices available to you regarding accepting or declining the use of cookies. For further information on how we use, store and keep your personal data secure, see our privacy policy which you can find under Privacy policy.

The Website is operated by Symprove B.V., a company incorporated in the Netherlands in the Netherlands with KVK number 87225522 and whose registered office is Locatellikade 1, 1076 AZ Amsterdam.

Legal basis

The legal basis for the data processing is our legitimate interest pursuant to Article 6(1) of the GDPR. The legitimate interest is to operate our Website in compliance with the law, and to be able to manage your consent or refusal to the use of cookies. The legal basis for the use of non-technical cookies is your consent pursuant to Article 6 (1) sentence 1 lit. a GDPR.

What are cookies?

Cookies are small pieces of data stored in text files that are saved on your computer or other devices when websites are loaded in a browser. Some features of our Website cannot be provided without the use of technically necessary cookies. Other cookies enable us to carry out various analyses. We use cookies to facilitate and improve your use of our Website. Among other things, cookies allow us to make our Website more user-friendly and effective for you. They are widely used to remember you and your preferences, either for a single visit (through a "Session Cookie") or for multiple repeat visits (using a "persistent cookie"). However, cookies do not cause any damage to your device. They cannot run programs or contain viruses. Our website uses different types of cookies, the nature and function of which are explained below:

1. Session Cookies are temporary cookies that are used during the course of your visit to the Website, and they expire when you close the web browser. Session Cookies store a session ID that can be used to associate different requests from your browser with the same session. This allows your browser to be recognised when you return to the website.
2. Persistent cookies are used to remember your preferences within our Website and remain on your desktop or mobile device even after you close your browser or restart your computer. They ensure a consistent and efficient experience for you while visiting the Website and Services by saving certain default settings so that they are available the next time you visit the site.
3. Third party cookies: Cookies may be set by the Website ("First-Party Cookies"), or by third parties. Third-party providers are service providers with whom we work together to provide the website. These include, for example, advertising networks or reach measurement who serve content or provide advertising or analytics services on the Website ("Third Party Cookies"). These third parties can recognize you when you visit our website and also when you visit certain other websites. You may learn more about cookies and how they work in this guide.

What type of cookies do we use?

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

The information below sets out the cookies we use and the reasons for usage:

1. Necessary cookies
   Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our Website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account to access the content.
2. Functionality cookies
   Functionality cookies let us operate the Website and Services in accordance with the choices you make. For example, we will recognize your username and remember how you customized the Website and Services during future visits.
3. Analytical cookies
   These cookies enable us and third party services to collect aggregated data for statistical purposes on how our visitors use the Website. These cookies do not contain personal data such as names and email addresses and are used to help us improve your user experience of the Website.
4. Social media cookies
   Third party cookies from social media sites (such as Facebook, Twitter, etc) let us track social network users when they visit or use the Website and Services, or share content, by using a tagging mechanism provided by those social networks.
   
   These cookies are also used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our and social networks’ Privacy policy. We will not collect or share any personally identifiable information from the user.

What are your cookie options?

If you do not approve of cookies or specific types of cookies, you can change your browser's settings to delete cookies that have already been set and to not accept new cookies. For further information about cookies and how to disable them please visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features the Website and Services offer. In some cases, however, there may be functional limitations.

Changes and amendments

We reserve the right to modify this Policy or its terms relating to the Website and Services at any time, effective upon posting of an updated version of this Policy on the Website. When we do, we will notify you and we will revise the updated date at the bottom of this page. Continued use of the Website and Services after any such changes shall constitute your consent to such changes.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

Contacting us

If you would like to contact us to understand more about this Policy, wish to receive or access information that we or third party providers collected (Articles 13-15 GDPR) or wish to contact us concerning any other matter relating to our use of cookies, you may send an email to privacy@symprove.com.