PRIVACY POLICY, COOKIES, AND EU DATA PROTECTION NOTICE
Vita Inclinata Technologies, Inc. (“Vita”, “us”, “we” and “our”) is committed to protecting and respecting your privacy. Accordingly, we have established the following Privacy Policy regarding the protection of your personal information when you visit our website https://vitatech.co (the “Site” or the “Website”) and/or preorder our LSS technology (the “LSS”) through the Website pre-order form, in accordance with the UK Data Protection Act 2018 and the EU General Data Protection Regulation 2018/679 (“Data Protection Law”). This Privacy Policy (and any other documents referred to in 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.
For the purposes of Data Protection Law, Vita acts as the data controller in respect of your personal data. If you have any questions, complaints or other enquiries about this Privacy Policy and our use of your personal data, we can be reached by the Contact Form on this Website.
We reserve the right to amend or modify this privacy statement at any time and in response to changes in applicable law. If we change our Privacy Policy, we will post the changes on this page and may place notices on other pages of our Website, so that you are aware of any amendments.
1. COLLECTION OF PERSONAL INFORMATION AND REQUESTS FOR CONSENT
1.1 We need to collect certain personal details from you when you use the Site, submit preorders for our LSS technology or when any other inquiries are made through our Site to maintain our quality standards. These details may include your name, email address, contact details and other basic information (together, “Customer Personal Data”). You can amend or update the information you have entered into the Site at any time by contacting us through email or telephone.
1.2 By registering your details on the Site you acknowledge that we may process your Customer Personal Data and contact you in order to fulfil our contract to you as a Customer.
1.3 By registering your details on the Site as a free user, you acknowledge that we may also process your Customer Personal Data and contact you via email or telephone, for the purposes of providing you with relevant information pertaining to our Site, and ensuring you are happy with the level of performance you are receiving from our LSS technology. This processing is undertaken on the basis of our legitimate interest of ensuring a quality standard of service to our Customers.
1.4 Provided that you consent to receiving such communications, we may send you promotional emails about our own or third parties’ product developments, new products or special offers, or other information which we or they think you may find interesting, or for market research purposes, as defined at the point of consent. You have the right to retract this consent and opt out of the aforementioned marketing communications at any time.
1.5 Visitors to our Website have the opportunity to download content by providing basic information including an email address (“Visitor Personal Data”). By registering your details on the Site in order to download information as a Visitor you are able to provide clear consent to the processing and use of your Visitor Personal Data for a specific purpose, as defined by us at the point of providing that data.
1.6 We will not share, trade or sell your personal data to any company or parties not directly associated with its proper use within the Site or as described above, except when you give us explicit consent.
1.7 We collate information about site traffic, sales, interaction data and other commercial information which we may use for internal purposes but this information does not include any information which can identify you personally.
1.8 In certain circumstances we may have a legal obligation to disclose personal data, and we reserve the right to do so.
1.9 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
2. HOW WE STORE, PROCESS AND TRANSMIT YOUR PERSONAL DATA
2.1 Customer Personal Data will be held by Vita using appropriate safeguards to maintain its privacy and security. However, it should be noted that data transfers take place over Wi-Fi or mobile networks over which we have no control. Email address details are only stored on our password-protected Website.
2.2 Your information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). Any Personal Data you provide may be used by a subsidiary or an affiliate entity within the Vita corporate family, partner entities and vendors and service agencies that we may engage to assist us, who may operate outside the EEA. Vita will not otherwise provide your personal data to a third party without obtaining your prior consent, except in case of providing it to (a) successors in title to our business; or (b) a third party pursuant to laws or regulations; or (c) in order to enforce or apply the Terms and Conditions; or (d) to protect the rights, property or safety of others; or (e) as outlined in this Privacy Policy.
2.3 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
2.4 The transfer, storage or processing of personal data outside the EEA does not diminish your rights and we will take all reasonable steps necessary to ensure that any information that is transferred, stored or processed outside the EEA will be treated securely, in accordance with this Privacy Policy and with the same level of protection required by Data Protection Law.
2.5 The transmission of information via the internet is not completely secure. Although we do our best to protect Customer Personal Data, and we cannot guarantee the security of your data whilst it is being transmitted to or from our Website; any transmission is at your own risk.
3. RETENTION OF YOUR DATA
3.1 We will retain Customer Personal Data for one year after the Customer has submitted any requests or inquiries regarding Vita’s LSS technology or other inquires with Vita.
3.2 We will retain Visitor Personal Data for two years after the point at which it was submitted to our Website or the last email contact with that individual.
4. YOUR RIGHT TO REQUEST INFORMATION
4.1 Under certain circumstances, you have the right to: (i) request copies of all personal data processed by us relating to you; (ii) request correction of personal data processed by us; (iii) a object to our processing of your personal data; (iv) request restriction of processing your personal data; (v) request transfer of your personal data; and (vi) erasure of any personal data (except that processed based upon legal obligation or public task). You also have the right to withdraw consent for us to process your personal data based upon this consent. You can request erasure or withdraw consent at any time via the contact form on this Website. We will not charge for initial requests, but may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
4.2 For security reasons we may ask for proof of your identity before we disclose information about you, or to you, via email or over the telephone.
5. LINKS TO THIRD PARTY SITES
5.1 The Website may from time to time provide links to other third party websites, whose privacy practices may differ from those of Vita. This Privacy Policy does not apply to those websites. If you submit personal data to any of those websites, your information is governed by their privacy policies and we do not accept any responsibility or liability in respect of third party websites. Please ensure you check the legal and privacy policy sections of any third party websites you may access through the website before submitting personal data to them.
6. CHANGES TO THE PRIVACY POLICY
6.1 Please note that this Privacy Policy may be revised at any time, so users are encouraged to visit this page every time they visit the Website. This Privacy Policy was last reviewed on June 24, 2019.
7. COLLECTION OF TECHNICAL DATA AND COOKIES
7.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
7.2 The Site uses cookies to:
(a) distinguish you from other users of the Website;
(b) remember searched locations for quick future reference by visitors; and
(c) save login information.
7.3 This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website. By using the Website, you are agreeing to our use of cookies.
7.4 We may use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.
(b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognize you when you return to the Website. This enables us to personalize our content for you, greet you by name and remember your preferences.
(d) Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them below:
Session cookie. This cookie allows users to stay logged into the Website whilst using it. This cookie is essential for the Website as it enables us to manage communication between our servers. The session cookie contains the API key and an expiry time stamp. When the user logs out the cookie is destroyed.
Google Analytics Tracking. This cookie allows us to analyze Site usage. This cookie does not store information that can be used to identify individual users.
7.5 By using this Website, you agree that we can place these types of cookies on your device.
7.6 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies and do not collect any additional personal data.
7.7 You have the option to set your browser to either accept cookies openly, to notify you before accepting cookies, or to refuse cookies altogether. If you refuse cookies please note that certain Website functionality, such as remembering your preferences, will not be available and you may not be able to access all or parts of the Website.
7.8 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
