Introduction

This Privacy Policy was developed to inform you about:

• how we collect information from You;
• Why we collect information from You;
• who we share your information with;
• how You can control Your own data;
• how to contact us;
• what your rights are.

Your privacy and the security of your personal data are very important to us, so we collect and manage your personal data with the utmost care and take specific measures to keep it safe. This policy may be subject to changes and additions over the time, so we invite you to check the contents periodically. We will strive to inform you immediately of any changes made.

Processing of Your personal data is carried out by personal data controller - Demareti Limited, a Private Limited Company, incorporated in United Kingdom, with registration number 7701173 on the 9th of April, 2011 (hereinafter – “we”/”the Company”). Demareti Limited, being personal data controller, is responsible for ensuring processing of personal data according to current legislation.

Should you need to contact us please write to the following e-mail address: [email protected]

This Privacy Policy applies to information collected through this website lifewise.cptpoint.net and any mobile sites, applications, widgets, and other interactive features that link to this Privacy Policy (collectively, the "Site"). This privacy policy was last updated on 10th of July, 2019.

You can contact us at any time by sending a request to our Customer support by e-mail: [email protected]

What data do we process?

The personal data that we collect from You is that:

(a) which you provide to us (through the Site or otherwise) when you:

• fill in the form for concluding distributor’s and any other contract;
• place the order for purchasing of any products/services offered on the Site;
• fill in shipping and/or payment instructions;
• subscribe for newsletters/offers/loyalty programs and

(b) which we collect as you browse or use any of the offers/services on the Site.

Through above provided means/sources we can collect personal details such as:

• name and surname;
• gender;
• Date of birth;
• Telephone number, contact e-mail addresses;
• shipping address, billing address or address of residence;
• payment details;
• browsing data and your purchase habits, such as the pages you visit and how you interact with them.

In some circumstances, you may have provided personal data relating to other individuals (such as your spouse, family members or other third party including minors). You represent and warrant that you are authorized to provide their personal data to us and you have obtained their consent to the collection, use, disclosure and processing of their personal data in accordance with this Policy.

In the event that you provide personal data of third parties to us, we will arrange for the third party to deliver the privacy notice at the time of the first communication.

For what purposed do we collect and process Your personal data?

We collect and process Your personal data for the following purposes/in order to:

1. To conclude and execute the Distributor’s Contract;
2. To handle Your orders:
   • process Your orders, notify You of Your order status, provide you with the products/services provided on the Site;
   • to be able to carry out identification and age verification;
   • manage payments;
   • manage returns, complaints and provide other Customers Services.

   Legal basis: Fulfillment of contractual obligations undertaken before you. Some of collected information will also be required for legal reasons such as fraud prevention and for our legitimate interests of defending against any claims made against us.

3. To administer Your user account:
   • to be able to carry out identification and age verification;
   • set up registration to the Site and use of services, reserved for registered users;
   • enable you to follow purchase and payment history;
   • manage Your settings;
   • execute analysis in order to be able make suggestions for shopping list in compliance with Your previous shopping history.

   Legal basis: Fulfillment of loyalty programs, contractual obligations undertaken before you. Some of collected information will also be required for legal reasons such as fraud prevention and for our legitimate interests of defending against any claims made against us.

4. To manage your requests forwarded to Customers Service:
   • to be able to communicate with You and respond Your inquiries;
   • Investigate complains;
   • to be able to carry out identification and age verification.
   • to provide you with information about your relationship or transactions with us.

   Legal basis: Legitimate interest, i.e.in order to be able to satisfy your and our interest to manage customer service cases.

5. To fulfill legal obligations:
   • detect, investigate and report financial crime;
   • to fulfill legal obligations as may be required by laws, judgements or administrative;
   • decisions (for example information/alerts about products’ recall/hazard).

   Legal basis: Legal obligations.

6. Undertake Site personalization and administration; provide benefits/offers to Yuo:
   • Provide personally adapted content by giving suggestions or other similar measures to simplify things for You;
   • Offer general and personal benefits, invitations to events or gifts or other direct marketing;
   • Carry out analyzes of the information the collected data in order to be able to provide; personal offers, benefits and communication;
   • to allow you to use, communicate and interact with others on our Site.

   Legal basis: Your consent and our legitimate interests of serving relevant adverts to you to get you to come back to our Site and see our offers.

7. To prevent and investigate crimes against the company:
   • Investigate/prevent fraud or other offences;
   • To prevent spam, unauthorized logins to user accounts and other prohibited actions;
   • improve IT environment against any attacks.

   Legal basis: Legal obligation and legitimate interest in preventing and investigating crimes against the company.

8. Evaluate and improve our services, products, systems:
   • Make services more friendly (such as: changing interface; simplifying information nflow etc);
   • Develop and improving products’ range, planning new stores/warehouses/IT systems etc.

   Legal basis: legal requirement of preventing fraud and our legitimate interests of ensuring that Site works effectively and in accordance with our customers’ browsing habits.

9. For our internal business purposes, such as logistics planning, demand forecasting, management information and research data, analysis, surveys, audits, developing new products/services, enhancing our Site, improving our services, identifying usage trends, and determining the effectiveness of our promotional campaigns.

   Legal basis: Performance of our contract with you. Our legitimate interests of ensuring we are targeting our customers effectively, provide the best possible services we can.However, only with your express consent will we process your personal data to:

   1. carry out commercial and promotional communication activities. to tell you about products, services, programs, and offers that we believe may be of interest to you via e-mail, SMS, telephone or postal mail;
   2. customize the site and the commercial offers based on your interests, i.e. personalize your experience as of registered user on Site, proposing previews and offers in line with your tastes and/or send you communications customized to your interests. Your Taste is determined by analyzing your previous purchases and other information, collected by us as provided above.

Should you wish to authorize the activities referred to in points (a) and (b) and subsequently do not wish to receive further communications from us or would like to limit the way in which to be contacted, you may cancel these communications at any time by clicking on the appropriate unsubscribe link at the bottom of each communication or by contacting our Customer Service.

You may receive further communications from us even after submitting your unsubscription request, as our systems may take some time to process your request.

In relation to all the activities mentioned above, we will process your personal data mainly through IT and electronic means.

Sharing of Your information

We do not, and will not, sell any of your personal data to any third party. However, we may share your data with/transfer for necessary processing to the following companies that we collaborate with :

• Companies, belonging to the group to which Data Controller belongs, as sometimes different group companies are responsible for different activities;
• Companies that do things to get your purchase/provide services to you, such as payment processors, other service providers, warehouses, order packers, and delivery companies;
• IT companies and other who support our Site and other business systems
• Professional service providers, such as marketing agencies, advertising partners and Site hosts who , who help us run our business;
• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud;
• Companies that provide marketing, distribution, transportation services etc.

Some of the third parties listed above may be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission.

We will put in place an appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information in case Your personal data is transferred to countries that do not belong to the European Union and that do not ensure adequate levels of protection.

How long do we keep your data?

We keep your personal data for a limited period of time depending on the purpose for which it was collected. This means that information is removed when it is no longer relevant or necessary for analyses or direct marketing or the purposes for which it was collected.

The retention period is different depending on the processing purpose. For example, the data collected during the purchase of products/services is processed until the conclusion of all administrative and accounting formalities (ten years) meanwhile that data which is used to send you promotional communication - until you ask us to stop sending it.

Your rights

You are entitled to:

1. access to your personal data and information about how we process/use it.

   If You want to find out more about the personal data that are being processed, you have the right to request access to Your data. If we receive a request for access, we may ask for additional information to make sure that information you wish to access shall be disclose it to the right person.

2. revoke your consent to the processing.
3. request the update, correction of processed personal data;
4. request cancellation, the limitation of processing or oppose their processing.

   You have such right if data is no longer necessary in relation to purpose for which it was collected or You object to processing for purposes of direct marketing. However there may be reasons for us not to satisfy such your request if there are legal obligations that prevent us from doing so.

5. If you believe that the processing of your personal data has been carried out illegally, you can file a complaint with one of the supervisory authorities responsible for compliance with the rules on personal data protection. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

   If you have any general questions about your rights or want to exercise please write to the following e-mail address : [email protected]

Regarding cookies

By continuing using the Site you are agreeing to our use of cookies in the manner described herein below.

You can choose whether or not to continue accepting Cookies at any later time.

What are Cookies?

Cookies are small text files that are is sent to the browser and saved on your device when you visit a Site. Internet browser sends the Cookies back to the Site on each your visit, allowing the Site to recognize your computer or device. This enables us to:

• observe your activity on the Site;
• deliver a personalized service and improve the Site;
• To allow you to securely sign in to your account;
• To store the content of your online shopping bag whilst you browse the site and to complete an order;
• To record the areas of the Site that you have visited, products you have viewed and time spent browsing, as well as the products you purchased;
• For re-marketing purposes (i.e to determine relevant related products to show you when you're browsing on other selected websites). These cookies can be associated with services provided by a third party such as an advertising network.
• We may also offer you the possibility to share your experience on our Site through social media sites such as Facebook and Twitter. By using these features, you are consenting to allow cookies from these providers.

Cookies are not harmful and do not contain any information such as your home address, date of birth or credit card details.

Which cookies do we use and for what purposes?

We use following cookies:

1. Strictly Necessary Cookies?

   These Cookies enable you to move around the Site and use essential features. For example, if you log into the Site, we use a Cookie to keep you logged in and allow you to access restricted areas, without you having to repeatedly enter your login details. If you are registering for or purchasing a product or service, we will use Cookies to remember your information and selections, as you move through the registration or purchase process. Strictly Necessary Cookies are necessary for our Site to provide you with a full service. If you disable them, certain essential features of the Site will not be available to you.

2. Performance Cookies

   Performance Cookies collect information about how you use our the Site (which pages you visit; do you experience any errors etc). These Cookies don’t collect any information that could identify you – all the information collected is anonymous. We may use these Cookies to help us understand how you use the Site and assess how well the Site performs and how we could improve it for you. We may also use such Cookies to discover which parts of the Site interest you and measure how effective our advertising is.

3. Functionality Cookies

   Functionality Cookies enable a Site to remember choices you make to your settings or preferences (for example, changes to text size or your choice of language or region) and provide enhanced, more personal features. You can control whether or not Functionality Cookies are used, but disabling them may mean we are unable to provide you with some services or features of the Site.

4. Targeting or Advertising Cookies

   These cookies assist in targeted advertising. We may use these Cookies to provide information about your Site visit to advertisers, so that they can show you adverts more relevant to your interests. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. We also use them to measure the effectiveness of our marketing communications. You can control whether or not these Cookies are used, but disabling them may mean we are unable to provide you with some services or features of the Site.

First and Third Party Cookies

The Cookies placed on your computer or device are ‘First Party’ Cookies, meaning Cookies that are placed there by us, or by third party service providers acting on our behalf. Where such Cookies are being managed by third parties, we only allow the third parties to use the Cookies for our purposes.

The Cookies placed on your computer or device may also include “Third Party Cookies”, meaning Cookies that are placed there by third parties. These Cookies may include third party advertisers who display adverts on our Site.

Managing Cookies

You always have a choice over whether or not to accept Cookies. If you choose not to allow the use of cookies, your experience of our Site will be limited and many integral aspects of the Site, including (but not limited to) adding items to your shopping bag and accessing your account, will not work at all.

If You want to change your cookie settings, or be notified each time a cookie is used or otherwise manage Cookies You should do this through the settings of your internet browser. You can choose to block or restrict Cookies from being placed on your computer or device. You can also review periodically he Cookies that have been placed there and disable them.

You can learn more about how to manage Cookies on the following websites: www.allaboutcookies.org and www.youronlinechoices.com

Web Analytics Services

We may use Google Analytics, a service for the marketing analysis of the site provided by Google, Inc.

Google Analytics uses cookies to allow us to see how you use our site so we can improve your experience. Google’s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy available at http://www.google.com/policies/privacy/. You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

Adobe Flash

We may provide videos and other content through the Site using Adobe Flash Player, which uses Cookies to provide useful features such as auto-resume and the ability to save your preferences. Flash Cookies are placed on your computer or device in much the same as other Cookies. However, it is not possible to manage them in the same way through your internet browser settings.

Links

Sites may contain links to other web sites. Please note that we do not accept liability for misuse of any information by any website controller to which we may link. We encourage you to read carefully the privacy statements of linked sites. If you take advantage of an offer from one of our partners, you may be providing information directly to that partner. Therefore we encourage you to review their privacy statements and offer as we are not responsible these.