A. General
In order to ensure better comprehensibility, our privacy policy does not differentiate between genders. For the purposes of equal treatment, relevant terms apply to both sexes.
The meaning of the terms being used, such as “personal data” or “processing” may be found in Article 4 of the EU General Data Protection Regulation (GDPR).
Personal data of the user processed within the scope of this online offer include inventory data (e.g. name and address of customers and end users), contract data (e.g. utilised services, names of officers, payment information), usage data (e.g. visited websites of our online offer, interest in our products) and contact data (e.g. contact form entries).
“User” hereby comprises all categories of persons whose data are processed. These include, for example, our business partners, customers, end users, interested parties and other visitors of our online offer.
B. Specific
Privacy Policy
We warrant that we shall only collect, process, store and use your existing data in relation to the handling of your requests, posts or messages, as well as for internal purposes and for the provisions of services you requested and to provide content.
Bases of Data Processing
We process the user’s personal data only in accordance with the relevant data protection provisions. User data are processed only in the event of the following legally permissible instances:
- to provide our contractual services (e.g. processing of orders) as well as online services
- the processing is required by law
- on the basis of your consent
- based on our legitimate interests (i.e. interest in the analysis, optimisation and cost-effective operation and security of our online offer within the meaning of Art. 6(1)(f) of the GDPR, particularly when measuring reach, profiling for advertising and marketing purposes, as well as the collection of access data and use of third-party services)
We would like to show you where the above legal bases are regulated in the GDPR:
| Consent | Art. 6(1)(a) and Art. 7 of the GDPR |
| Processing in order to provide our services and implement contractual measures | Art. 6(1)(b) of the GDPR |
| Processing in order to fulfil our legal obligations | Art. 6(1)(c) of the GDPR |
| Processing in order to protect our legitimate interests | Art. 6(1)(f) of the GDPR |
Transfer of Data to Third Parties
Transfer of data to third parties is carried out only in accordance with legal requirements. We forward user data to third parties only if this is required, for example, by contract or on the basis of legitimate interest in the cost-effective and efficient operation of our business activities.
If we employ subcontractors for the provision of our services, we shall take the required legal precautions as well as the corresponding technical and organisational measures to ensure the safety of personal data in accordance with the applicable legal regulations.
Data Transfer to Third Countries or International Organisations
Third countries are those countries in which the GDPR is not a directly applicable law. This basically covers all countries outside the EU or the European Economic Area.
Data are transferred to a third country or an international organisation. It must be noted that there are relevant/corresponding warranties available and that you may exercise enforceable rights and effective legal remedies.
A copy of the corresponding warranties may be found at the following links:
- Privacy-Shield: https://www.privacyshield.gov/list
- Standard contractual clauses:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF
Storage Duration of Your Personal Data
We adhere to the principles of data minimisation and data reduction. This means that we shall store the data you provided to us only so long as it takes to fulfil the above purposes or as required by various statutory storage periods. If the relevant purpose is not applicable, or the corresponding term expires, your data shall be routinely blocked or erased according to legal regulations.
Establishing Contact
You may contact us by phone at the number: +49 7164 9300 or by fax at the number: +49 7164 930297. If you contact us via our contact form or by e-mail, e.g. Datenschutz@wala.de, you agree to electronic communications. When you establish contact with us, personal data shall be collected. In the corresponding contact form, you may find which types of data are collected when using a contract form. Your data shall be sent using SSL encryption. The information you provide shall only be stored for the purpose of processing requests, posts or messages and for possible follow-up questions.
We would like to specify the relevant legal bases:
| Processing in order to provide our services and implement contractual measures | Art. 6(1)(b) of the GDPR |
| Processing in order to protect our legitimate interests | Art. 6(1)(f) of the GDPR |
We use a software to maintain customer data (CRM system) or a comparable software on the basis of our legitimate interests (efficient and fast processing of user requests). The system is operated by us in-house. Therefore, data are not transferred to third parties.
We would like to point out that any e-mails you send, including those you send to WALA, may be unknowingly read or modified without authorisation along the transmission path. We also emphasise that we use spam filter software. The spam filter may reject e-mails if some characteristics are mistakenly interpreted as spam.
What rights do you have?
a) Right of Access
You have the right to obtain free access to your stored data. Upon request, we shall inform you in writing, pursuant to the applicable law, on which personal data about you we have stored. This also includes the origin and the recipient of your data as well as the purpose of data processing.
b) Right to Rectification
You have the right to have inaccurate data concerning you, which is stored by us, rectified. You may also request the restriction of processing, e.g. when contesting the accuracy of your personal data.
c) Right of Blocking
Furthermore, you may have your data blocked. In order to consider the blocking of your data at any moment, the data must be kept in a locked file for control purposes.
d) Right to Erasure
You may also request the erasure of your personal data, provided there are no statutory retention periods. If such an obligation is applicable, we shall block your data upon request. If the required legal prerequisites are met, we shall erase your personal data even without your corresponding request.
e) Right to Data Portability
You have the right to receive the personal data concerning you, which you provided to us, in a format that enables transfer to another authority.
f) Right to Lodge a Complaint with a Supervisory Authority
You have the option to lodge a complaint with a supervisory data protection authority.
The state data protection and freedom of information officer of Baden-Wuerttemberg
Mailing address: Postfach 10 29 32, D-70025 Stuttgart
Home address: Königstraße 10a, D-70173 Stuttgart
Telephone: +49 711 615541–0
Fax: +49 711 615541–15
E-mail: poststelle@lfdi.bwl.de
Web: https://www.baden-wuerttemberg.datenschutz.de
You may access the complaint form via the following link:
https://www.baden-wuerttemberg.datenschutz.de/online-beschwerde
g) Right to Object
At any moment, you have the option to cancel the use of your data for internal purposes with future effect. To achieve this, you are only required to send an e-mail to datenschutz@wala.de. However, such a cancellation does not affect the lawfulness of the processing carried out up to that moment by us. This does not affect data processing in relation to any other legal bases, e.g. contract initiation (see above).
In order to ensure better comprehensibility, our privacy policy does not differentiate between genders. For the purposes of equal treatment, relevant terms apply to all sexes.
The meaning of the terms being used, such as “personal data” or “processing” may be found in Article 4 of the EU General Data Protection Regulation (GDPR).
Personal data of the user processed within the scope of this online offer include inventory data (e.g. name and address of customers and end users), contract data (e.g. utilised services, names of officers, payment information), usage data (e.g. visited websites of our online offer, interest in our products) and contact data (e.g. contact form entries).
“User” hereby comprises all categories of persons whose data are processed. These include, for example, our business partners, customers, end users, interested parties and other visitors of our online offer.
A. General
In order to ensure better comprehensibility, our privacy policy does not differentiate between genders. For the purposes of equal treatment, relevant terms apply to all sexes.
The meaning of the terms being used, such as “personal data” or “processing” may be found in Article 4 of the EU General Data Protection Regulation (GDPR).
Personal data of the user processed within the scope of this online offer include inventory data (e.g. name and address of customers and end users), contract data (e.g. utilised services, names of officers, payment information), usage data (e.g. visited websites of our online offer, interest in our products) and contact data (e.g. contact form entries).
“User” hereby comprises all categories of persons whose data are processed. These include, for example, our business partners, customers, end users, interested parties and other visitors of our online offer.
B. Specific
Privacy Policy
We warrant that we shall only collect, process, store and use your existing data in relation to the handling of your requests, posts or messages, as well as for internal purposes and for the provisions of services you requested and to provide content.
Bases of Data Processing
We process the user’s personal data only in accordance with the relevant data protection provisions. User data are processed only in the event of the following legally permissible instances:
to provide our contractual services (e.g. processing of orders) as well as online services
the processing is required by law
on the basis of your consent
based on our legitimate interests (i.e. interest in the analysis, optimisation and cost-effective operation and security of our online offer within the meaning of Art. 6(1)(f) of the GDPR, particularly when measuring reach, profiling for advertising and marketing purposes, as well as the collection of access data and use of third-party services)
We would like to show you where the above legal bases are regulated in the GDPR:
Consent
Art. 6(1)(a) and Art. 7 of the GDPR
Processing in order to provide our services and implement contractual measures Art. 6(1)(b) of the GDPR
Processing in order to fulfil our legal obligations Art. 6(1)(c) of the GDPR
Processing in order to protect our legitimate interests Art. 6(1)(f) of the GDPR
Transfer of Data to Third Parties
Transfer of data to third parties is carried out only in accordance with legal requirements. We forward user data to third parties only if this is required, for example, by contract or on the basis of legitimate interest in the cost-effective and efficient operation of our business activities.
If we employ subcontractors for the provision of our services, we shall take the required legal precautions as well as the corresponding technical and organisational measures to ensure the safety of personal data in accordance with the applicable legal regulations.
Data Transfer to Third Countries or International Organisations
Third countries are those countries in which the GDPR is not a directly applicable law. This basically covers all countries outside the EU or the European Economic Area.
Data are transferred to a third country or an international organisation. It must be noted that there are relevant/corresponding warranties available and that you may exercise enforceable rights and effective legal remedies.
Storage Duration of Your Personal Data
We adhere to the principles of data minimisation and data reduction. This means that we shall store the data you provided to us only so long as it takes to fulfil the above purposes or as required by various statutory storage periods. If the relevant purpose is not applicable, or the corresponding term expires, your data shall be routinely blocked or erased according to legal regulations.
Establishing Contact
You may contact us by phone at the number: +49 7164 9300 or by fax at the number: +49 7164 930297. If you contact us via our contact form or by e-mail, e.g. Datenschutz@wala.de, you agree to electronic communications. When you establish contact with us, personal data shall be collected. In the corresponding contact form, you may find which types of data are collected when using a contract form. Your data shall be sent using SSL encryption. The information you provide shall only be stored for the purpose of processing requests, posts or messages and for possible follow-up questions.
We would like to specify the relevant legal bases:
Processing in order to provide our services and implement contractual measures Art. 6(1)(b) of the GDPR
Processing in order to protect our legitimate interests Art. 6(1)(f) of the GDPR
We use a software to maintain customer data (CRM system) or a comparable software on the basis of our legitimate interests (efficient and fast processing of user requests). The system is operated by us in-house. Therefore, data are not transferred to third parties.
We would like to point out that any e-mails you send, including those you send to WALA, may be unknowingly read or modified without authorisation along the transmission path. We also emphasise that we use spam filter software. The spam filter may reject e-mails if some characteristics are mistakenly interpreted as spam.
What rights do you have?
a) Right of Access
You have the right to obtain free access to your stored data. Upon request, we shall inform you in writing, pursuant to the applicable law, on which personal data about you we have stored. This also includes the origin and the recipient of your data as well as the purpose of data processing.
b) Right to Rectification
You have the right to have inaccurate data concerning you, which is stored by us, rectified. You may also request the restriction of processing, e.g. when contesting the accuracy of your personal data.
c) Right of Blocking
Furthermore, you may have your data blocked. In order to consider the blocking of your data at any moment, the data must be kept in a locked file for control purposes.
d) Right to Erasure
You may also request the erasure of your personal data, provided there are no statutory retention periods. If such an obligation is applicable, we shall block your data upon request. If the required legal prerequisites are met, we shall erase your personal data even without your corresponding request.
e) Right to Data Portability
You have the right to receive the personal data concerning you, which you provided to us, in a format that enables transfer to another authority.
f) Right to Lodge a Complaint with a Supervisory Authority
You have the option to lodge a complaint with a supervisory data protection authority.
The state data protection and freedom of information officer of Baden-Wuerttemberg
Mailing address: Postfach 10 29 32, D-70025 Stuttgart
Home address: Königstraße 10a, D-70173 Stuttgart
Telephone: +49 711 615541–0
Fax: +49 711 615541–15
E-mail: poststelle@lfdi.bwl.de
Web: https://www.baden-wuerttemberg.datenschutz.de
You may access the complaint form via the following link:
https://www.baden-wuerttemberg.datenschutz.de/beschwerde/
g) Right to Object
You have the right at any time to object to the processing of your data, which is processed on the basis of the legitimate interest of the person responsible for data processing. To achieve this, you are only required to send an e-mail to datenschutz@wala.de. However, such an objection does not affect the lawfulness of the data processing carried out up to that moment by us. This does not affect data processing in relation to any other legal bases, e.g. contract initiation (see above).
h) Right of withdrawal in the case of consent given
You have the right to revoke your consent to data processing at any time. However, such a revoca-tion does not affect the legality of the processing operations that have taken place up to that point. Data processing with regard to all other legal bases remains unaffected by this.
Protection of Your Personal Data
We employ contractual, organisational and technical safety measures, with due regard to the state of the art, in order to ensure adherence to the provisions of data protection laws and for the protection of data that we process against accidental or intentional manipulation, loss, destruction and access by unauthorised persons.
These safety measures especially include the encrypted transfer of data between your browser and our server. For this purpose, we use 256-bit SSL encryption (AES 256). This includes your IP address.
Your personal data are thereby protected under the following items (excerpt):
a) Maintaining confidentiality of your personal data
In order to keep the confidentiality of your personal data stored with us, we have taken various measures to control access and entry.
b) Maintaining integrity of your personal data
In order to maintain the integrity of your personal data stored with us, we have taken various measures to control forwarding and input.
c) Maintaining availability of your personal data
In order to maintain the availability of your personal data stored with us, we have taken various measures to control orders and availability.
The safety measures being used are constantly improved in line with technological development. Despite these precautions and due to the insecure nature of the Internet, we cannot guarantee the safety of your data transfer to our online offer. Consequently, any data transfer you perform to our online offer is at your own risk.
According to Art. 6 para. 1 item (b) of the GDPR, personal data shall be collected and processed if you provide them to us for the performance of a contract or the opening of a customer account. The respective entry forms may be inspected to determine which data are being collected. The deletion of your customer account is possible at any moment and may be carried out by sending a notification to the above-mentioned address of the responsible person. We store and use the data you provided for contract performance. After full performance of the contract or the deletion of your customer account, your data shall be blocked with regard to tax and commercial statutory retention periods and erased after the expiration of these periods, unless you have expressly consented to further use of your data or if we reserve the right to a legally permitted further use of data of which you shall be duly informed below.
Forwarding of Personal Data for Contract Performance
As part of contract performance, the personal data collected by us shall be forwarded to the transport company commissioned with the delivery, insofar this is necessary for the delivery of goods. To effect payments, we forward payment data to the commissioned credit institution.
If you have given us your express consent for this in the ordering process, we will give your e-mail address to our transport service provider in accordance with Art. 6 para. 1 item (a) of the GDPR before the delivery of the goods for the purpose of coordinating a delivery date or for delivery notification. In case of delivery of the goods by DHL to Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn, in case of delivery by GLS to General Logistics Systems Germany GmbH & Co. OHG, GLS Germany-Straße 1-7, 36286 Neuenstein.Otherwise, we will only pass on the name of the recipient and the delivery address to our transport service provider for the purpose of delivery in accordance with Art. 6 para. 1 item (b) of the GDPR. The disclosure is made only to the extent necessary for the delivery of goods. In this case, prior coordination of the delivery date with the transport service provider or delivery notification is not possible. The consent can be revoked at any time with effect for the future to the person responsible named above or to the transport service provider.
Payment Methods
When paying via PayPal, by credit card via PayPal, by debit note via PayPal or, if offered, "Kauf auf Rechnung" (purchase on account) via PayPal, we shall forward the payment data, in order to effect payments, to PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). PayPal reserves the right to conduct a credit report with regard to the payment methods including credit card via PayPal, debit note via PayPal or, if offered, "Kauf auf Rechnung" (purchase on account) via PayPal. The result of the credit check with respect to the probability of default on payment is used by PayPal to decide on the provision of the respective payment method. The credit report may include probability values (so-called score value). If score values are included in the results of the credit report, they are based on a scientifically recognized mathematical and statistical procedure. The calculation of score values includes, among other things, mailing address data. For further legal data protection information, which may also include the credit agencies used, please refer to the privacy policy of PayPal: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
If you decide to use the payment service provider Stripe for credit card payment, SOFORT Überweisung or giropay/paydirekt, the payment shall be effected by the payment service provider Stripe Payments Europe, 1 Grand Canal Street Lower, IRL Dublin, to whom we shall forward the information communicated during the ordering process along with the information about your order. Your data is forwarded exclusively for the purpose of effecting payments via the payment service provider Stripe.
Sofortüberweisung
When paying using SOFORT, we immediately receive the transfer credit note. For this purpose, you shall provide SOFORT GmbH (Sofort GmbH, Theresienhöhe 12, D-80339 München) with the bank account number, bank code, PIN and TAN via the secure payment form which we cannot access. SOFORT GmbH provides automated and real-time transfer to your online bank account. The due purchase amount shall be transferred immediately and directly to our bank account. If you choose the Sofortüberweisung payment method, a pre-filled form shall open at the end of the ordering process containing our bank details. The due transfer amount as well as the purpose of use shall also be entered. In the form you must specify the country in which the online banking account is located and the bank code. In order to execute the Sofortüberweisung transfer, you must enter the account number and PIN to log in to the online banking account and provide confirmation by entering the TAN. The transaction shall be confirmed immediately. In general, every user may choose Sofortüberweisung as their payment method, if they have an active online banking account with a PIN/TAN procedure. Take note that certain banks do not have the Sofortüberweisung option available. For further information, please refer to the provider's website: https://www.klarna.com/sofort
Credit card
A simple and fast processing of your order is guaranteed when paying with a credit card. All you have to do is enter your credit card number and the 3–4-digit control number on the back of the credit card and the date on which the credit card expires. If your credit card is protected by the MasterCard 3D-Secure or Verified by Visa systems, you will be redirected to a secure website of your credit card issuing bank where you will have to enter the protection code. As soon as the credit card is accepted, the payment shall be considered as effected. The shipping of your items will be activated as soon as the credit card is accepted.
Giropay/Paydirekt
Based on online banking with PIN and TAN numbers, it enables you simple, fast and secure payment using online money transfer. To use Giropay, you only need an online banking giro account at a participating bank or savings bank. Giropay allows you to conduct your online money transfers in the secure online banking environment of your credit institution. This guarantees that sensitive data (PIN/TAN) shall only be exchanged between you and the bank. No third person shall have insight in the personal account and turnover information.
Giropay operates in the following manner: If you decide to pay using Giropay, you will be safely directed to the online banking system of your bank or savings bank after entering your bank code. There you will log in as usual with your access data. Having successfully logged in, a pre-filled money transfer order shall automatically be displayed, already containing all the details of the purchase: invoice amount, reason for payment and bank code of the dealer. You authorize the money transfer by entering TAN. Directly after a successful money transfer, we shall receive a payment guarantee from your bank and be able to send the goods immediately, depending on availability.
Klarna (Purchase on invoice)
We offer the possibility for our customers to select the payment service provider Klarna for payment. In this case, the payment is processed via Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter "Klarna"). The personal data (first name and surname, street, house number, postcode, town, gender, e-mail address, telephone number and IP address) of our customers, as well as data relating to the order (e.g. invoice amount, article, delivery type) are passed on to Klarna for the purpose of checking identity and creditworthiness, insofar as consent has been expressly given in accordance with Art. 6 Para. 1 lit. a) GDPR during the ordering process. The credit agencies to which personal data may be forwarded as part of the credit check can be viewed here:
https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/credit_rating_agencies.
The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. Klarna uses the information received about the statistical probability of a payment default for a weighed decision about the establishment, implementation or termination of the contractual relationship.
The consent can be revoked at any time by sending a message to WALA Heilmittel GmbH or to Klarna. However, Klarna may still be entitled to process the personal data if this is necessary for the contractual processing of payments.
Further information on the processing of data by Klarna can be found at the following link: https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/privacy.
You can rate our Dr. Hauschka products. For this purpose, you shall enter in the contact form your name, e-mail address and IP address, a summary of your topic and your rating in the form of stars (1-5) and your opinion, if necessary.
All participants are required to give their surname, name and e-mail and IP address, so that serious forum posts may be posted on the forum. Your e-mail address will not be disclosed. By pressing the “Informed consent” button, the participant provides their consent for the collection and processing of data, which may be health data. The participant makes these willingly available to WALA for release. WALA Heilmittel GmbH collects, processes and uses your personal data expressly to operate the rating forum and stores them to document the forum posts. Ratings and posts are also occasionally published on this online offer, e.g. for product advertising. Personal data shall not be made available to third persons.
Your rights as a participant in the ratings forum: You may request information regarding which data are stored about you. You may request the rectification, erasure and blocking of your personal data, provided this is legally permissible and possible under an existing contractual relationship. You may object to prevent (further) publication of your own posts. You may also withdraw your consent for the storage of your data at any moment. In these cases, you may send your objection to the following address: datenschutz@wala.de
Privacy Policy
This privacy policy sets out how WALA UK uses and protects your personal data. It’s important to us that you understand what goes on with your data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
Privacy policy
This privacy policy gives you information about how WALA UK collects and uses your personal data through your use of this website, including any data you may provide when you register with us, sign up to our newsletter, purchase a product or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
WALA UK LIMITED is the controller and responsible for your personal data (collectively referred to as "WALA", "we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
We use different methods to collect data from and about you including through:
• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us (including leaving a product review)
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Legal basis and retention period |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you We will retain this data for 6 years. |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) We will retain this data for 6 years |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you We will retain this data for 6 years. |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data for 6 years. |
| To link your skin test results with your account | (a) Identity (b) Contact (c) Profile
| (a) Your consent We will retain this data until you withdraw your consent. |
| To enable you to partake in our Loyalty Programme | (a) Identity (b) Contact (c) Profile (d) Usage (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data for 6 years. |
| To allow you to rate our Products on the Website | (a) Identity (b) Contact (c) Profile (d) Usage (d) Transaction (e) Marketing and Communications | (a) Necessary for our legitimate interests (to study what our customers think about our products/services, to develop them and grow our business) We will retain this data for 6 years |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) 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) (b) Necessary to comply with a legal obligation We will retain this data for 6 years. |
| To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | 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) We will retain this data for 6 years. |
| To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical (b) Usage | 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) We will retain this data for 6 years. |
| Receiving information relating to adverse effects of our Products | (a) Identity (b) Contact (d) Transaction
| (a) Necessary for our legitimate interests (for understanding the effects of our products and improving them) (b) Necessary to comply with a legal obligation We will retain this data for 6 years. |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) And/or Consent, having obtained your prior consent to receiving direct marketing communications We will retain this data for 12 years. |
| To carry out market research through your voluntary participation in surveys | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
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Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at info@wala.co.uk.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product, updates to our Terms and Conditions, checking that your contact details are correct.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see [LINK TO YOUR COOKIE POLICY].
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Service Providers who assist us in providing our Website and Services being:
o Dr Hauschka Germany (WALA Heilmittel GmbH) with its registered office at Dorfstraße 1
D - 73087 Bad Boll/Eckwälden;
o Splio SAS with its registered office at 27 boulevard des Italiens, 75002 Paris, France
o von Affenfels GmbH (who provide IT support) with its registered office at Kronenstraße 40, 70174 Stuttgart
o DPD GROUP UK LTD with its registered office at Roebuck Lane, Smethwick, West Midlands, B66 1BY
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data within the WALA Group. This will involve transferring your data outside the UK to our overseas offices in the European Union.
We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, such as countries within the EEA.
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection by only transferring your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, countries within the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us and see Contact details (paragraph 10).
No fee usually required
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. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
• Email address: info@wala.co.uk
• Postal address: 32 Beaumont Street, Oxford, OX1 2NP
• Telephone number: 0800 0556604
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
