Privacy Policy

ABOUT YOUR PERSONAL DATA

INFORMATION ABOUT YOUR PERSONAL DATA

Please be advised that Vitamix Healthcare Products LLC (with its address at Büyükdere cad. No:127, Astoria A Kule, Kat:8, Esentepe, Şişli, İstanbul, Turkey, recognizes and respects your rights regarding usage of your personal data, and is committed to and does its best for the protection thereof.

Vitamix Healthcare Products LLC is dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with the Turkish Personal Data Protection Law no. 6698, EU General Data Protection Regulation (GDPR), and UK Data Protection Act 2018 including its applied GDPR provisions (DPA 2018). Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.

This Privacy Policy applies to personal data that Vitamix Healthcare Products LLC may collect about you through its websites, apps, or other online media under its operation and control (collectively, the “Website”) and to other information we may collect about you in the course of our business.

How do we collect personal data?

As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. You are allowed to manage and limit the cookies we collect on our Website. 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.

What categories of personal data do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). A data subject is the individual who the personal data relates to.

We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Notice.

Personal data: Here is a list of personal data we commonly collect to conduct our business activities.

• Contact details (e.g., name, company name, job title, work and mobile telephone numbers, email and postal addresses, IP address).
• Internet (e.g., browsing history, search history, and information regarding your interaction with our Website).
• Financial information (e.g., taxes, bank details).
• Transaction data, including details about products and/or services that you have purchased from us.
• Marketing and communications information, including your preferences in receiving marketing from us.

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 our Website. Usage data includes information about how you use our Website, products and services.

What lawful reasons do we have for processing personal data?

We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:

Contract: We may process personal data in order to perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals.

Consent: We may rely on your freely given consent at the time you provided your personal data to us.

Legitimate interests: We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced and your interests and fundamental rights do not override those interests.

These may include:

• managing and developing our relationship with you and the organization that you represent,
• protecting the security and integrity of our premises, Website and other information technology systems (including protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity),
• responding to and communicating with you about your requests, questions and comments,
• operating, evaluating and improving our business,
• comply with our corporate and corporate social responsibility commitments.

Legal obligations: We may process personal data in order to meet our legal and regulatory obligations or mandates. Also, for protecting ourselves and our employees and business counterparties against fraud and other criminal activity, and co-operating with law enforcement and other regulatory agencies.

Public interest: We may process personal data in order to perform a specific task in the public interest or in the exercise of official authority vested in us.

Vital interests: We may process personal data to protect the vital interests of the individual or another natural person.

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 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.

Vitamix Healthcare Products LLC does not trade, sell or rent personal data but may collect or provide aggregate statistics about its Website and their users to other parties who do not provide services directly to Vitamix Healthcare Products LLC.

Why do we need personal data?

Please be assured that Vitamix Healthcare Products LLC will act responsibly and with due diligence in handling any data and information about yourself either given by you to us or made available to and collected by us on the occasion of your visit to our Website. You should also be advised that any data and information made available to and collected by Company on the occasion of your visit to its Website, may be stored, processed or transferred by it for the purpose of:

• protecting the rights, titles and security of Vitamix Healthcare Products LLC or of any third parties;
• complying with legal or regulatory obligations;
• collecting and/or providing statistical bulk data and information about the Website or the visitors or users thereof;
• sharing news bulletins and financial reports of Vitamix Healthcare Products LLC.

However, Vitamix Healthcare Products LLC is committed not to use, or sell or lease to third persons, your personal data for commercial purposes without your explicit consent.

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:

• Providing our products and services to you and for customer service-related purposes.
• Administering, maintaining and ensuring the security and efficiency of our information systems, applications and Website.
• Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
• Carrying out our duties described under Legitimate Interests given above.
• Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage.
• Collecting health data to assess, monitor and control spread of infectious diseases and to provide a safe environment for our employees, clients and suppliers.

Marketing

You may 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 that marketing.
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
You have the right to opt out of receiving marketing communications at any time. Please contact us if you wish to do so.

Do we share personal data with third parties?

We will not share your information with any third parties for the purposes of direct marketing. Vitamix Healthcare Products LLC may disclose your personal information to technology and other service providers, including professional advisors, who hold and process the information on their behalf. Vitamix Healthcare Products LLC is required to safeguard personal data in accordance with contractual obligations and data protection legislation.

Vitamix Healthcare Products LLC may also disclose your personal information if it has a good faith belief that this is necessary for the legal and compliance purposes set out above. For these purposes, we may, for example, disclose information about you to courts and litigation counterparties, insurers, the police and other competent governmental authorities.

We only allow third parties to handle your personal data if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

In any scenario, we will satisfy ourselves that we have a lawful basis on which to share the information and document our decision making and satisfy ourselves we have a legal basis on which to share the information.

We may also need to share personal data with external auditors to ensure compliance with legal and regulatory requirements, with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations and with potential buyers of some or all of our business or during a restructuring.

Do we transfer your personal data outside the UK or European Economic Area (EEA)?

If your personal information is collected or processed within the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), you should be aware that the disclosures described above may include transfers of your personal information to recipients outside the EEA or the UK, including recipients in countries (such as the Turkey). Personal information transferred to Vitamix Healthcare Products LLC entities in the Turkey is protected by the Turkish Personal Data Protection Law no. 6698, which was developed in accordance with the GDPR. Where your personal information is transferred to to third party service providers in countries without strict data privacy laws, the information will be protected by data transfer agreements in the appropriate form approved for this purpose by the European Commission.

Do we use cookies?

Our Website may use cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

By law, we may not place cookies on your computer without your consent, unless they are strictly necessary to the operation of the service that we provide on the Website.

We use Google Analytics to monitor how our Website is being used so we can make improvements. Our use of Google Analytics requires us to pass to Google your IP address (but no other information) – Google uses this information to prepare site usage reports for us, but Google may also share this information with other Google services. In particular, Google may use the data collected to contextualize and personalise the ads of its own advertising network.

What are your data protection rights?

If you would like to exercise your Data Subject Rights, you can wright us using the form on the Website. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

• Access: You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
• Correction: You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
• Erasure: You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
• Processing restrictions: You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
• Data portability: In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
• Right to withdraw consent: You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.

If you would like to exercise any of these rights, please contact us, providing enough information to identify yourself and letting us know which right you would like to exercise and the information to which your request relates.

What about personal data security?

We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.

How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to.

We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in respect of the services.

Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for ten (10) years.

Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to: Vitamix Healthcare Products LLC, Büyükdere cad. No:127, Astoria A Kule, Kat:8, Esentepe, Şişli, İstanbul, Turkey or you can wright us using the form on the Website. We aim to respond within 30 days from the date we receive privacy-related communications.