Privacy policy
- INTRODUCTION
This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data and keep it safe as well as explaining your privacy rights and how the law protects you. We know that there's a lot of information here, but we want you to be fully informed about your rights, and how OP Health Limited, and its group companies, uses your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.
This Privacy Policy applies to all our websites, including any websites on sub-domains, extensions and locales we own, and any online platforms, applications and software systems we operate including but not limited to https://op-health.co.uk/ (our "sites").
It's likely that we'll need to update this Privacy Policy from time to time. Wherever possible we'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish.
- WHO IS OP HEALTH LIMITED?
OP Health Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this Privacy Policy).
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below:
Email us at privacy (at) admin@op-health.co.uk
We manufacture and sell our OP Health products throughout the world. This policy applies to you if you are one of our customers, distributors, trainers, therapists or suppliers (or if you work for any of these organisations), candidates for a job with us, or if you are a visitor to our sites. For the purposes of this policy:
Articles – means any of our products or services.
Business Customer – means one of our business customers who purchase any Articles from us or from one of our Distributors.
Candidate – an individual who is applying for a job or for work with us in any capacity including for employment, freelance work, an apprenticeship, internship or otherwise.
Customer – means an individual end-customer who purchases or enquires about any Article from us, from one of our Distributors or from one of our Business Customers or otherwise, or who otherwise corresponds or interacts with us about our Articles.
Employer – means any corporate or unincorporated entity or any other person that employs or engages a Representative.
Distributor – means one of our appointed distributors authorised to sell any of our Articles.
Distributor Shareholders – means the shareholders of our Distributors.
Official OP Health Stockist – means any business which has a valid and subsisting authorisation from us to use the designation "Official OP Health Stockist".
Representative – means any person who acts as an employee, director, officer, partner, contractor or agent of one of our Distributors, or of any other Business Customers.
Supplier Personnel – business contacts in our supplier organisations.
Therapist – means any person who provides any beauty or other treatment using any of our Articles.
- WHAT SORT OF PERSONAL DATA DO WE COLLECT?
Personal data, or personal information, means any information about an individual from which that person can be directly or indirectly identified. It does not include data where the identity has been removed (anonymous and pseudonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity and Contact Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of Articles you have purchased from us and may include your payment card details and/or bank account details.
Candidate Data includes your CV, covering letter and application form, details of your qualifications, skills, experience and employment history, details of your current level of remuneration and benefit entitlements, your entitlement to work in the UK, your photograph and information you provide to us during your interview.
Representative Data includes names, addresses, contact and identity details (including social media handles, profile picture and any ratings (whether given by consumers, us or others)) of any Representative.
Distributor Shareholder Data includes names, addresses and details of shareholdings of the Distributor's shareholders.
Technical and Usage 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 and other technology on the devices you use to access one of our sites, and information about how you use our sites.
Profile Data includes your site username and password (encrypted), purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special categories of data includes (1) in respect of Customers, a Customer's health details or philosophical beliefs and information in relation to a complaint of an adverse reaction to any of our Articles (including any photo thereof and the Customer's profile picture), and (2) in respect of Candidates, whether or not a Candidate has a disability for which we need to make reasonable adjustments during the recruitment process, and information about a Candidate's race or ethnicity, religious beliefs, sexual orientation and political opinions for equal opportunities monitoring purposes.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific site feature. However, if we combine or connect Aggregated Data with your personal data 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. Our sites are not intended for children under the age of 18 and we do not knowingly collect data relating to children under the age of 18.
- HOW DO WE COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you.
A. Customers
Direct Interactions. You may give us your Identity and Contact Data, Profile Data, Transaction Data, Marketing and Communications Data and/or Special Categories of Data when you visit our sites to purchase or enquire about our Articles, create an account with us or purchase an Article by phone but don't have (or don't use) an account. You may also give us your information when you engage with us on social media, contact us by any means with queries or complaints, enter prize draws or competitions, complete any surveys, comment on or review our Articles or request marketing information from us.
Information from third parties. We may receive your Identity and Contact Data, Profile Data, Customer Data, Marketing and Communications Data and Special Categories of Data from third parties.
B. Representatives
Direct Interactions. You may give us your Identity and Contact Data, Representative Data, Transaction Data, Marketing and Communications Data when your Employer enters into an agreement with us, when you purchase our Articles from the OP Health website.
Information from third parties. We may receive your Representative Data from publicly available sources, such as Companies House. We may also receive Representative Data from your Employer, or from social media platforms.
C. Candidates
Direct Interactions. You may give us your Identity and Contact Data, Candidate Data and Special Categories of Data by sending your application and CV to us and when you attend interviews or complete other forms of assessment.
Information from third parties. We may receive Identity and Contact Data and Candidate Data from third parties such as your employer, third party databases or from your recruiter.
D. Supplier Personnel
We collect your Identity and Contact Data and Financial Data when we correspond with you about our services, and from publicly available sources such as Companies House.
E. Distributor Shareholders
We collect your Distributor Shareholder Data from our Distributors and from publicly available sources such as Companies House.
F. Automated technologies or interactions:
As you interact with our site, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, traffic logs and other similar technologies. Please see our cookies policy for further details, a copy of which can be found by accessing the 'Cookies Policy' link within the footer of the site from which you accessed this Privacy Policy.
- HOW DO WE USE YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter or have entered with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The legitimate interests we rely on are set out next to each purpose below. Where we need to comply with a legal or regulatory obligation.
To find out more about the types of lawful basis that we will rely on to process your personal data see section 6.
Generally we do not rely on consent as a legal basis for processing your personal data other than where we send third party direct marketing communications to you via email or text message, where we provide your details to third parties for their direct marketing purposes, communicating with Customers in respect of Customer complaints, or where a Customer provides us with special categories of personal data in order to purchase an Article from us, from one of our Distributors or from one of our Business Customers or otherwise. You have the right to withdraw consent to marketing at any time by contacting us, details are in section 2.
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 Articles). In this case, we may have to cancel an Article you have with us, but we will notify you if this is the case at the time.
- WHY DO WE USE YOUR PERSONAL DATA, WHAT LEGAL BASES DO WE RELY ON?
We have set out below, in a table format, a description of all the ways we plan to use 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (see section 2) if you need details about the specific legal ground, we are relying on you to process your personal data where more than one ground has been set out in the table below.
|
Category |
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
Customer |
To register you as a new customer, to process and deliver your order (including managing payments and collecting money owed to us) |
(a) Identity and Contact |
(a) Performance of a contract with you |
|
Customer |
To manage our relationship with you which will include: |
(a) Identity and Contact |
(a) Performance of a contract with you |
|
Customer |
To investigate customer complaints (which may involve us processing your health data), including any complaints you make to one of our distributors and to enable us to make improvements to our Articles |
(a) Identity and Contact |
(a) Performance of a contract with you |
|
Customer |
To establish, exercise or defend legal claims made against us, to provide our insurance company with relevant details of any claim or potential claim and to contact third party experts to understand the scientific basis behind any claim or potential claim |
(a) Identity and Contact |
(a) Necessary for the establishment, exercise or defence of legal claims |
|
Representative |
To carry out our contractual obligations to your Employer, including to: (d) Manage payments, fees and charges, and collect monies owed to us |
(a) Identity and Contact |
Necessary for our legitimate interests in:
|
|
Candidate |
To consider you for a role, if you are applying for a job with us, including: |
(a) Identity and Contact |
(a) Necessary to take steps at your request prior to entering into a contract with you, or to enter into a contract with you |
|
Distributor Shareholders |
To manage our relationship with our Distributors and for accounts and record keeping purposes |
(a) Distributor |
Necessary for our legitimate interests in managing our distribution contracts and for record keeping purposes |
|
Supplier Personnel |
To carry out our contractual obligations to our suppliers, including to manage our payments to such suppliers |
(a) Identity and Contact |
Necessary for our legitimate interests in receiving products and services from our suppliers to ensure our business is run efficiently |
|
All site users and visitors |
To administer and protect our business and this site’s (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(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) |
|
All site users and visitors |
To deliver relevant site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
Necessary for our legitimate interests (to study how customers use our Articles, to develop them, to grow our business and to inform our marketing strategy) |
|
All Site users and visitors |
To use data analytics to improve our site, Articles, marketing, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our Articles, to keep our site updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity and Contact, Technical and Usage, Profile Data and OP Health Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Articles and offers may be relevant for you (we call this marketing).
If you are a site visitor but are not one of our Customers, you will receive marketing communications from us if you have consented to do so. You may opt out of receiving such marketing at any time. Formally, where we process your personal data to send you marketing communications based on your consent, we rely on the 'consent' legal basis under data protection laws to do so.
If you are a Customer, you will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. Formally, where we process your personal data to send you these marketing communications on the basis that it is in our 'legitimate interests' to do so.
If you are a Representative, you will receive marketing communications from us unless you have opted out of receiving such marketing. Formally, where we process your personal data to send you these marketing communications on the basis that it is in our 'legitimate interests' to do so.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an Article purchase, warranty registration, Article experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- HOW WE PROTECT YOUR PERSONAL DATA
We know how much data security matters to all our Customers, Candidates, Representatives, Supplier Personnel and to anyone who visits or uses one of our sites. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
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 secure access to all transactional areas of our sites using 'https' technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.
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 WE KEEP YOUR PERSONAL DATA?
Whenever we collect or process your personal data, we'll only keep it for as long as is necessary for the purpose for which it was collected, 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.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
- WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may share your personal data with our group companies. We sometimes share your personal data with trusted third-party service providers.
Examples of the kind of third-party service providers we work with are:
IT companies who support our site and other business systems.
Our payment processor, which collects and processes Customer payments on our behalf.
Operational companies such as delivery couriers (e.g. Royal Mail).
Direct marketing companies who help us manage our electronic communications with you (e.g. Mailchimp). Google/Facebook to show you products that might interest you while you're browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our sites. See our cookies policy for details, a copy of which can be found by accessing the 'Cookies Policy' link within the footer of the site from which you accessed this Privacy Policy.
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.
Here's the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and always protected. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
We may also disclose your personal data to 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.
Finally, we may also be required to disclose your personal data in order to comply with applicable law, or to respond to valid legal process from law enforcement or other government agencies, or to protect the users of our sites to prevent spam or attempts to defraud them, or to operate and maintain the security of our sites (e.g. to prevent or stop an attack on our systems or networks).
- WHERE YOUR PERSONAL DATA MAY BE PROCESSED
Sometimes we will need to share your personal data with third parties and suppliers outside the UK or the European Economic Area (EEA), such as the United Arab Emirates.
Protecting your data outside the UK or the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK or the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the UK or the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact our Data Protection Officer (see section 2).
Any transfer of your personal data will follow applicable laws, and we will treat the information under the guiding principles of this Privacy Policy.
- WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
An overview of your different rights
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases. The correction of your personal data when incorrect, out of date or incomplete. That we stop using your personal data for direct marketing (either through specific channels, or all channels).That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact the Data Protection Officer via email at admin@op-health.co.uk To ask for your information to be amended, please update your online account, or contact our Customer Services team.
If we choose not to action your request we will explain to you the reasons for our refusal.
In certain specified situations you also have the right to request us to port (i.e. transmit) your personal data directly to another organisation, to request your personal data be 'erased' and the right not to be subject to decisions based solely on the basis of automated processing (if applicable). Please contact the Data Protection Officer using the details set out above if you would like any further information on your rights.
Your right to withdraw consent Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request.
Checking your identity To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may 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.
- HOW CAN YOU STOP THE USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING?
There are several ways you can stop direct marketing communications from us:
- Click the 'unsubscribe' link in any email communication that we send you. We will then stop any further emails from that particular division.
- If you have an account on any site, you may be able to change your preferences within the 'Settings' or 'My Account' area of the particular site.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
- CONTACTING THE REGULATOR?
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns. Please note we can't be responsible for the content of external sites.
- ANY QUESTIONS?
We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven't been covered, please contact the Data Protection Officer using the details set out below:
Email us at admin@op-health.co.uk
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.
Cookie Policy
Our cookies policy
To make full use of the online shopping and personalised features on https://www.op-health.co.uk, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain personalised features of this website by using them.
You are in control. If at any time, you'd prefer to restrict, block or delete cookies from https://www.op-health.co.uk, (or any other website for that matter), you can easily use your browser to do this.
Each browser is different, so check the 'Help' menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences.
If you don't wish to enable cookies, you'll still be able to browse the site and use it for research purposes, but it won’t be possible to order or login to an account.
What are cookies
Cookies are tiny text files stored on your computer when you visit certain web pages. At https://op-health.co.uk/ we use cookies to keep track of what you have in your basket, and to remember you when you return to our site.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Our cookies do not store sensitive information such as your name, address or payment details: they simply hold the 'key' that, once you're signed in, is associated with this information. Cookies can't harm your computer.
What we use cookies for
We use four categories of cookies on our website.
- Strictly Necessary
- Performance
- Functionality
- Targeting
Strictly Necessary cookies
Strictly Necessary cookies are required for the operation of our website. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website and ordering.
Our use of Strictly Necessary cookies includes
- identifying you as logged in to the secure parts of our website during your visit;
- remembering information, you have previously entered to complete a form (e.g. retrieval of an order in your account) as you proceed through a journey on our website; and
- ensuring we comply with your instructions, for example, we use a ‘compliance cookie’ to store your decision on whether you accept or reject cookies so that we cannot follow your wishes.
We do not use these cookies to:
- track your internet activity on other websites; or
- collect information about you for marketing purposes
Some examples of Strictly Necessary cookies used on our website are:
|
Name of cookie |
Function |
|
i.e. Cart |
i.e. Used in connection with shopping cart. |
|
i.e. _tracking_consent |
i.e. Tracking preferences. |
Performance cookies
Performance cookies collect more detailed information about how visitors use our website.
Just as a manager of a physical retail shop will monitor the shopping area to understand what customers like and want (and what they don’t), so responsible website operators like ourselves use performance cookies to improve the way our website looks and works. We have set our Performance cookies so that data is either anonymous or pseudonymous.
We do not know your full IP address.
Our use of Performance Cookies includes:
- analysing how visitors use our website;
- recording any errors that occur; and
- testing different designs of our website.
Some examples of Performance cookies used on our website are:
|
Name of cookie |
Function |
|
i.e. ga, gat, gid, __utmt_* |
i.e. Google Analytics to monitor traffic levels, search queries and visits to this website. |
|
i.e. _landing_page |
i.e. Track landing pages. |
At the time of writing, we understand that Hotjar honours ‘do not track’ settings. For more information, including details of how to block these Google Analytics cookies specifically, please see https://tools.google.com/dlpage/gaoptout/.
Functionality cookies
Functionality cookies are used to provide services (such as to watch embedded YouTube videos or chat live to customer service).
Our use of Functionality cookies includes:
- allowing you to watch embedded YouTube videos; and
- providing live chat functionality to you across our website.
Some examples of Functionality cookies used on our website are:
|
Name of cookie |
Function |
|
i.e. VISITOR_INFO1_LIVE*, PREF*, VSC*, remote_sid*, GEUP, s_gl, GPS, |
i.e. YouTube Videos |
Targeting Cookies
Targeting Cookies record your visit to our website, including the web pages you have visited and the links you have followed. We use this information to make our website and our advertising relevant to your interests. When visiting another website that displays adverts, you may see an advert that relates to our website instead of a generic advert in its place.
An example of a targeting cookie is our use of the Google AdWords remarketing service.
Information about how you can opt out of Google's use of cookies can be seen by visiting Google's Ads Settings. Alternatively, you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt out page.
Further information
If you'd like to learn more about cookies in general and how to manage them, aboutcookies.org (opens in a new window). Please note that we're not responsible for the content of external websites which includes all links listed in this Cookie Policy.
Our details
https://op-health.co.uk/ is owned and operated by OP Health Limited. We are registered in England and Wales under registration number 15869114, and our registered office is at 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF.
You can contact us:
- by email, using the email address published on our website.