Privacy Notice (Non US)

Last modified: 09.09.2020

SUMMARY OF HOW WE USE YOUR DATA

• What do we do with your information and what is the legal basis for this use?SVA Holding Co LLC and related entities (“SVA”), use your personal information to respond to your requests for information, inform you of our products and services and other purposes as set out in this notice.
• Disclosure: Data is shared with third party service providers and professional advisers that may be located outside the EEA.
• Consent: Where we rely on your consent, such as for marketing our products and services to you, use of cookies, and collection and use of your sensitive personal data, you may withdraw this consent at any time.
• Cookies: Our site uses cookies to track visitors using our site, analyse trends and usage patterns for research and marketing purposes. You are not obliged to accept cookies. More information is set out in the “Cookies and Web Beacons” section.
• Your rights: You have certain rights to your personal information under applicable laws, including a right to object to some of the processing which SVA carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

WHAT DOES THIS NOTICE COVER?

This is the Privacy Notice of SVA. It describes how we will make use of all Personal Information which you provide to us.

Please read this page carefully before you start to use this site. If you do not wish to be bound by this Privacy Notice then you should not access this site. Where permitted by law, access of this site by you shall be deemed to be your acceptance of this Privacy Notice and your agreement that we may process and use your personal information in accordance with this Privacy Notice.

If you have any queries regarding this Privacy Notice or complaints about our use of your information please contact us at [email protected] and we will do our best to deal with your complaint or query as soon as possible.

INFORMATION WHICH WE MAY OBTAIN ABOUT YOU

The types of personal information we may collect and process from you include:

• your contact information (e.g. name, telephone number, email address, postal address);
• information related to your product preferences subject to your prior and explicit consent as may be required under applicable law;
• if you contact us or our agents, we may keep a record of that communication and any communications and correspondence with you; and
• information about your computer, including where available, your IP address, operating system and browser type, for system administration and security reasons and to collect aggregate information. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

WHAT INFORMATION ABOUT YOU DO WE RECEIVE FROM THIRD PARTIES?

Sometimes, we receive information about you from third parties. In particular, we may receive information about you from our business partners such as physical or online retail points of sale of our products with whom you have direct contact.

The information we collect from such third parties include your contact information and information related to your client profile and product preferences.

WHAT WE DO WITH YOUR INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We may use the personal information you supply to us via our site for the following purposes:

• as required by SVA to conduct our business and pursue our legitimate interests, in particular:
• responding to requests which you have submitted via our site and to deal with on-going matters relating to such requests;
• presenting content from our site in the way that we consider most effective;
• providing you with information relating to SVA;
• monitoring customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
• using information you provide to investigate any complaints received from you or from others, about our website or our products or services;
• using data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
• where you give us consent:
• providing you with product-related information, promotional details about products and services that may be of interest to you, as well as personalised mailings (electronic or otherwise) or other communications;
• providing you with individualised product related information, products and services in accordance with information you provide regarding product preferences;
• placing cookies and using similar technologies in accordance with the “Cookies and Similar Technologies” section and the information provided to you when those technologies are used;
• on other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time.
• for purposes which are required by law, such as:
• in response to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing/profiling

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by contacting us using the details set out in “Opting Out” section below.

DISCLOSURE

In some cases we may be required to disclose your personal information to comply with legal requirements and requests from government agencies if required for the purposes set out above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws. We may also disclose your personal information to our related companies or to third parties:

• who provide us with data management and profiling, analytics, advertising or other services in order to provide information about tailored and individualized offers including on social media, and provide you with any information that you have requested;
• where we consider that we need to in order to comply with any law or regulation, where we suspect that any criminal offence may have been committed, to protect our rights, property or safety or that of others and in any circumstances where we consider that we are permitted to do so by law or regulation; and
• where that third party is a professional adviser to us or any of our related companies.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Our site may contain links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should therefore make sure when you leave our site that you have read that website’s Privacy Notice.

TRANSMISSION OF PERSONAL INFORMATION OUTSIDE EEA

The information you provide to us may be given to our third party service suppliers outside the European Economic Area for the purpose of delivering the personalized services and communications stated above. SVA will always take steps to ensure that your information is used by third parties in accordance with this Privacy Notice and that your information is kept secure at all times. In particular, in relation to any transfer to a third party in a country that is not subject to an adequacy decision by the EU Commission, such transfer will be appropriately protected through mechanisms such as EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review upon request.

Where permitted by law, if you do not consent to this transfer, then please do not register on our site as we will be unable to provide you with our services.

COOKIES AND SIMILAR TECHNOLOGIES

Our site uses cookies or similar technologies (e.g. web beacons). A “cookie” is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser (e.g. “Internet Explorer”). Each time you request a page from the website, your web browser sends this cookie back to the website server.

SVA uses the following cookies:

We may also use the information collected from our use of cookies to estimate our audience size, analyse trends and general usage patterns of our site, optimize our site, and for other research and marketing purposes. This is statistical information and does not identify any individual.

You are not obliged to accept cookies. If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users.

By using our site without disabling cookies via your browser settings you are consenting to our use of cookies and similar technologies as described in this notice.

Please note that our advertisers and third party partners may also use cookies. These parties may use so-called “third party” cookies so that they can track your response to their adverts and/or identify you on any other website that you visit which also contains their adverts. Please refer to their Privacy Notice for further details.

More information on cookies and similar technologies is available at the website www.allaboutcookies.org

WHAT RIGHTS DO I HAVE?

In accordance with applicable laws, you may have rights in relation to your personal information. Such rights include:

You have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing (see below “Opting Out”).

These rights may be limited, for example if fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in applicable data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an applicable data protection authority where you live, work or where you believe a breach may have occurred.

OPTING OUT

If you do not wish to remain on our database and to receive our personalized mailings (electronic or otherwise) or other communications, please note that you may opt out of our database by using the “Unsubscribe” option at the foot of our email communications, or by sending an email to our Data Protection Manager at the following email address: [email protected]

HOW LONG WILL YOU RETAIN MY DATA?

Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Where we process your financial information, we will only keep the information for as long as necessary for the purpose/s for which it is collected and up to two months thereafter.

In relation to all your other personal data including registration data, we will not retain your data for longer than required for the purposes indicated above, and will delete personal data if they are no longer necessary for the purposes for which they are collected or otherwise processed, unless we are required to keep the data to comply with applicable legal obligations.

QUERIES OR COMPLAINTS

If you have any queries or complaints regarding this Privacy Notice or use of your personal information please contact our Data Protection Manager using the contact details set out in the “Opting Out” section above.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

SVA Holding Co LLC

251 Little Falls Drive, Wilmington, 1908 Delaware, USA

[email protected]

WHICH ENTITY IS MY DATA CONTROLLER, AND WHICH AFFILIATES MIGHT MY DATA BE SHARED WITH?

The data controller for your information is :

SVA Holding Co LLC

251 Little Falls Drive, Wilmington, 1908 Delaware, USA

[email protected]

AMENDMENTS

We may update this Privacy Notice from time to time and we will notify you of any material changes using the email address you have provided upon registration or by an announcement on the site. The changes will apply to the use of the site after such notice. Where permitted by law, if you use the site after the date on which the changes come into effect, you will be deemed to have accepted the new Privacy Notice.

Website Privacy Policy (US Only)

Last modified: 09.09.20

Introduction

SVA Holding Co LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.SVAWell.com (the “Website” or “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you, this Website, and the Company, including any digital communications with our employees, agents, and representatives.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

California residents may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Children’s Privacy

This Website is not intended for or directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on the Website. If we become aware that a child under the age of thirteen has provided us with personal information, we will delete the information from our records.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, date of birth or age and any other identifier by which you may be contacted online or offline (“personal information”);
• That is about you but individually does not identify you, such as your product preferences; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. We may also ask you for information when you enter a promotion sponsored by us and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We currently do not change our tracking practices in response to “do-not-track” signals or other similar mechanisms. Third parties that have content or services on our Site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits. These third parties do not change their tracking practices in response to “do-not-track” signals from your web browser and we do not obligate these parties to honor “do-not-track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit https://allaboutdnt.com/.

The information we collect automatically is only statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information that you request from us.
• To communicate with you, including to respond to your inquiries or complaints, and to send you alerts.
• To fulfill any other purpose for which you provide it.
• To notify you about changes to our Website.
• To allow you to participate in interactive features on our Website.
• To provide you with product-related information, information related to the Company or promotional details about products, as well as personalized mailings (electronic or otherwise) or other communications.
• To operate and improve our business, including to conduct research and development, to develop new products and services, and perform accounting, auditing and other internal business functions.
• For analytics purposes, such as to understand how you use our Website, determine what browser and devices you use to visit our Website and to evaluate and improve our products, services, advertisements, and Website.
• For legal and security purposes, such as to detect, prevent, and prosecute harmful, fraudulent, or illegal activity, loss prevention, identify and repair bugs on our Website, and to comply with applicable legal requirements, relevant industry standards and our policies.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
• Other short-term, transient use.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact [email protected].

. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business based on your instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that provide web hosting services.
• To parties to a corporate transaction, such as a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SVA Holding Co LLC’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by SVA Holding Co LLC about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use https://www.svawell.com/terms-of-use/
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SVA Holding Co LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. The website allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users. We may also use analytics services, such as Google Analytics, on our Website to help us evaluate and analyze how visitors use our Website. For specific details on how Google collects and uses information on our Website, please visit: https://marketingplatform.google.com/about/analytics/terms/us/.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to [email protected].
• Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to [email protected].
• . If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to [email protected].
• . For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website (www.networkadvertising.org).

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Accessing and Correcting Your Information

You may send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Data Retention

We keep the personal information you provide for the duration of our relationship, plus a reasonable period of time thereafter.

Your California Privacy Rights

Disclosures of Personal Information

We disclose the following categories of personal information for business or commercial purposes:

• Contact information and personal identifiers.
• Device identifiers.
• Demographic information.
• Internet or other electronic network activity information.

These disclosures take place for the following business or commercial purposes:

• To audit our interactions with you to ensure compliance with applicable law and to measure the effectiveness of our products, services, and advertisements.
• To detect, prevent, and prosecute harmful, fraudulent, or illegal activity.
• To identity and repair bugs on our Website.
• To provide services.
• For research and development.
• To further our business goals, including to advertise our products and services.
• Short-term, transient use.

The disclosure of personal information for which we receive valuable consideration (i.e., the receipt of some benefit other than money) is considered a “sale.” We do not sell your personal information in connection with the Website.

Your California Privacy Rights

If you are a resident of California, you have the right to request the following details about personal information we have collected about you during the past 12 months:

• The categories and specific pieces of personal information we have collected about you.
• The categories and source from which we have collected personal information about you.
• The categories of personal information we disclosed about you for a business purpose.
• The categories of personal information we sold about you and the categories of third parties to whom it was sold.
• The business or commercial purpose for collecting or selling your personal information.

In addition, you have the right to request that we delete the personal information we have collected from you (subject to certain exceptions).

You can exercise your rights by contacting us at [email protected]. We will take reasonable steps to verify your identity when processing requests.

We will not discriminate against you on account of your exercise of your California privacy rights.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

International Transfers

We may transfer the personal information we collect about you to our affiliates and third-party service providers in countries other than the country in which the information was originally collected (including the United States), where necessary to fulfill the purposes described in this privacy policy, and your personal information may be processed and stored outside of your country of residence. Those countries may not provide the same level of data protection as your country of residence. When we transfer your personal information to other countries, we will protect that information in the manner described in this privacy policy. We have also implemented appropriate safeguards to ensure such a level of data protection when transferring your personal information, including the execution of data transfer agreements incorporating the European Commission’s Standard Contractual Clauses, or using U.S. service providers certified to the EU-U.S. Privacy Shield as set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use, and retention of personal information transferred from the European Economic Area to the United States, or other applicable data transfer mechanisms. You may obtain a copy of these data transfer mechanisms by contacting us as indicated below.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

SVA Holding Co LLC

251 Little Falls Drive, Wilmington, 1908 Delaware, USA

[email protected]