Data Protection Policy

Last updated: April 2023

Comvita respects the privacy of everyone who comes into contact with Comvita and we are committed to maintaining high standards of data protection compliance.

1. Why Am I Seeing This Message?

This data protection notice applies to all services and activities that we offer on the web, social media and apps and elsewhere, including our e-commerce store (the “Comvita Services”). It explains our approach and how we collect personal information provided to us or collected by us in connection with your use of the Comvita Services or any other interaction with Comvita.

This data protection notice also explains the legal basis on which we are allowed to process your personal information, your rights regarding our use of your personal information, how you can control what personal information is collected by us and how you request that we delete, update or transfer this information.

This data protection notice is intended to support you in making informed decisions when using the Comvita services. Please read it carefully and note that it should be read in addition to the Terms and Conditions.

2. Who Are We?

The Website is owned and operated by Comvita Europe B.V (“we”, “us”, “our” or “Comvita”).

Comvita is the data controller of your personal information.

Comvita is a company registered in the Netherlands with a registered company number: is an English company with registered company number: 82796912. The registered address is Bavincklaan 7, 1183 AT Amstelveen, the Netherlands.

3. How Can You Contact Us?

If you have any questions about this data protection notice or want to exercise your rights, please contact us: by email to [email protected]

Please contact us at [email protected] with any request different to our standard policy.

4. What Personal Information Do We Collect About Users And Viewers Of Comvita And How Do We Collect It?

Personal information may be collected from you in the following ways (see the section below for information on how and why we use the information):

• A. Information that you voluntarily provide to us directly.
• We collect and receive personally identifiable information that you voluntarily submit to us during your use of the Comvita Services or through other interactions with us. For example, when you register, sign up for a newsletter, participate in a survey or contest, submit content, post comments, or purchase goods through our websites.
• This can include:
• Surname;
• E-mail address;
• Address;
• City or country;
• Date of birth;
• Gender;
• favourite products, etc.;
• And may include information in content you submit:
• Your image or likeness (or that of others who also appear) in the Content you submit;
• Other information about yourself (or that of others that also appears) in the content you submit;
• Other information about yourself (or that of others who is also mentioned) in the messages you send to us.
• B. Information you voluntary provide to us through a social media login.
• We collect and store personal information from your social media profile that you voluntarily consent to providing to us when you register or log in, participate in a survey, etc. by using our social media login functionality (e.g. Facebook ) to use.
• This includes:
• Surname;
• Date of birth;
• Gender;
• Email address;
• Phone number.
• C. Information we collect through your use of the comvita service.
• Through our use of cookies and other technologies, we collect information about your use of and navigation through the Comvita Services, including emails from us to you, information about your mobile device, or the computer hardware and software that you used to access the access Comvita services.
• This includes the following information:
• IP address of the services used;
• Browser type;
• Operating system and device type;
• Approximate location (e.g. Berlin);
• Access times and dates;
• Addresses of the referring websites;
• Navigation on the site;
• Followed links, including in emails;
• Time spent on pages or viewing content;
• Types of content viewed and shared.
• For more information, please see the Data Analytics, Insight and Profiling sections below and our Cookies section.
• D. Information we receive from third party data sources and brand partners.
• We may also combine information we hold about you with information we receive from third parties, including brand partners and data aggregators. This information is used to determine your likely interests so that we can provide more relevant services to you. We always ensure that the provider of the information has the appropriate permission and legal basis for sharing such information with Comvita.
• For more information, please see the Data Analytics, Insight and Profiling sections below.
• E. Information we receive from third party partners.
• We may use third parties to provide additional services such as e-commerce, bookings or other retail or merchandise functionality. Typically, in such a situation, you will interact and contact such third parties directly. As part of this subcontracting solution, we receive information from our partners about your purchases. This includes your name and email address and other information such as the category of product purchased or the club, brand or event to which it belongs. This information is used by us to determine your likely interests so that we can provide more relevant services to you. Please also see the section below on "Comvita Shop / E-Commerce" for more information about the online shop on our site.
• For more information, please see the Data Analytics, Insight and Profiling sections below.

5. How Do We Use The Personal Information Of Comvita Users And Visitors?

In addition to the sections below, we transmit the collected data for processing to the relevant internal departments and other affiliated companies with the Comvita Group or to external service providers, and processors according to the required purposes.

In addition we use the information we collect from or about you for the following purposes:

• A. Provision of the Comvita service.
• We need your information to log you in, to verify who you are, to guarantee that you receive the service you have registered for, and to otherwise provide our services to you.
• What is our legal basis for this?
• This use of information is necessary for the delivery and performance of the contract between us, to provide you with the services for which you have registered.
• B. Sending newsletters or other types of communication (from Comvita) to which you have subscribed.
• In the event that you have given your consent, we use your personal information to send you newsletters and other marketing materials about Comvita products and services that may be of interest to you.
• What is our legal basis for this?
• We rely on your consent for these services, which you provided at the time you requested newsletters or other marketing materials.
• C. Conducting surveys, sweepstakes and/or other promotions.
• We collect and use your personal information in surveys, sweepstakes and/or promotions in which you participate.
• What is our legal basis for this?
• It is in our legitimate interests to use your personal information in this way to administer the survey, sweepstakes and/or promotion. Please note that we will only send you marketing information related to a promotion or survey with your consent.
• D. Data analytics, insight and profiles.
• We also analyse your personal information to what we know about you based on your interactions with our Comvita Service, our email communications with you and/or the products and services you have purchased or viewed, including any third party information, which we obtain as set out above.
• This information is used to generate profiles and insights about visits and usage habits of our services. This information allows us to measure the effectiveness of our content and how visitors use the Comvita Services. This allows us to learn, for example, which content and pages are most attractive to our users, which parts of our services are most interesting, and what type of information our users want to see.
• We also use this information to help select and generate future content and services.
• We also use this information to help select and deliver relevant advertising messages to you.
• We also use this information for social media marketing purposes (see sections below for more details).
• What is our legal basis for this?
• When your personal information is completely anonymised, we do not need a legal basis to use it as the information does not include "personal information" which is regulated under data protection laws. However, our collection and use of such de-identified personal information may be subject to other laws that require your consent. See the Cookies section below for more details and our Cookies Policy.
• If your personal information is not anonymised, it is in our legitimate interest to use your personal information in a way that allows us to provide you and other users with the best possible content and services.
• E. Social Media Remarketing.
• We use information we collect about you from your interactions with Comvita Services, our email communications with you, and/or our Content and Services (see the Data Analytics, Insights and Profiles section above for more details on the information collected and the manner of collection) in order to provide you with personalized content or advertising on social media channels operated by Facebook and/or Google if you are a registered user of these services.
• We do this using Facebook Custom Audiences and/or Google Customer Match respectively. Please note that such activities are also subject to the privacy choices you have made about those services.
• For this purpose we share your encrypted email address with Facebook and/or Google according to their Facebook Custom Audiences and/or Google Customer Match services. We do not allow them to use your information for any other purpose.
• What is our legal basis for this?
• When your personal information is completely anonymised, we don't need a legal basis to use it as the information no longer includes "personal information" which is regulated under data protection laws. However, our collection and use of such de-identified personal information may be subject to other laws that require your consent.
• See the Cookies Policy for more details.
• If your personal information is not anonymised, it is in our legitimate interests to use your personal information for these marketing purposes.
• F. Social Media Insight.
• If you are a registered user of Facebook or a Google service, we use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services (and show them ads), who have interests similar to yours. This is based on:
• Information we collect about you from your interactions with our Services, our email communications with you, and/or our Content and Services (see the Data Analytics, Insights and Profiles section above for more details on the information collected and the type of collection) received; and
• Information held by Facebook and/or Google about you.
• We do this using Facebook Custom Audiences and/or Google Customer Match respectively. Please note that such activities are subject to the privacy choices you have made about those services. Please note that Facebook and Google will not use your information for anything other than suggesting to us similar types of users of their services to which we can show ads; and we do not use your information to make any decisions about you.
• What is our legal basis for this?
• When your personal information is completely anonymised, we don't need a legal basis to use it as the information no longer includes "personal information" which is regulated under data protection laws. However, our collection and use of such de-identified personal information may be subject to other laws that require your consent. See the Cookies section below for more details.
• Where your personal information is not anonymised, it is in our legitimate interests to use your personal information for these interest generation purposes.
• G. Posting Content You Provide.
• If you provide us with content (e.g. photos or videos) to be included on our Services, we collect certain personal information from you when you provide the content and we use it in connection with sharing the content of benefit you. The content may also contain your personal information or that of other people who also appear or are mentioned in the form of images or other information that can identify you.
• What is our legal basis for this?
• This use of information is necessary for the delivery and performance of the contract between us, to provide you with the services for which you have registered. If you provide your content for these purposes, we consider it your consent to use your content and personal information in this way and confirmation that you have the consent of others appearing in the content.
• It is also in our legitimate interests to use your personal information in this way to perform the Services.
• H. service management.
• We also use your personal information:
• to improve the Comvita Services; and
• to contact you to respond to any inquiries you have sent to us.
• What is our legal basis for this?
• It is in our legitimate interest to use your personal information in this way to provide you with the best possible service.
• I. share information with third parties.
• We may share your personal information with third parties in order to provide you with the Comvita Services and related products and services. These include companies that host or manage our servers or databases as well as our subcontractors who manage the Comvita shop for us. These companies have no rights to use your data and are strictly contractually controlled by us.
• What is our legal basis for this?
• It is in our legitimate interests to share your personal information in this way in order to provide you with the best possible service.
• J. Company administration, documentation and legal certainty.
• We use your personal information for the following corporate governance and legal security purposes:
• to comply with our legal obligations;
• to enforce our legal rights;
• to protect the rights of third parties; and
• in connection with a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets.
• Such use may include sharing your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory bodies.
• What is our legal basis for this?
• It is in our legitimate interests to ensure that we keep our records up to date and use them in connection with a business transition, enforce our legal claim or protect the rights of others. Furthermore, it is our legal obligation to use your personal information in order to comply with any legal obligation imposed on us or other legal requirements to which we are subject.

6. Comvita Shop / E-Commerce

Comvita (as data controller) collects, uses and shares your data related to your use of the e-commerce store and in accordance with clauses 4 and 5 above and the other parts of the Data Protection Notice.

7. How Do We Obtain Your Consent?

If our use of your personal information requires your consent, you can provide that consent in the following ways:

• at the time we collect your personal information by following our instructions; or
• by informing us using the contact details in this data protection notice.

8. Use Of Cookies

The Comvita Services use certain cookies and other technologies that you should be aware of.

For further detail, refer to our Cookies Policy.

9. Third Party Links And Services

Comvita's services may contain links to third-party websites and services. We would like to point out that the validity of this data protection declaration expires if you use a link to go from the services of Comvita to another website or if you request a service from a third party.

Your browsing and interactions on other websites or your relationships with other third parties are governed by those websites' or third parties' own rules and policies.

We do not monitor, control, or endorse the privacy practices of third parties. We recommend that you familiarize yourself with the privacy practices of any website you visit or any third-party provider with which you have a relationship, and that you contact those third-party providers if you have any questions about their own privacy policies and practices.

10. Data Transfers Outside The EAA

In the course of our business activities or for legal reasons, we may transfer your personal data to processors outside the EEA. We will ensure that the transmission is lawful and that appropriate safeguards are in place.

If the European Commission has decided that a country does not offer an adequate level of data protection in relation to data transferred there, we will enter into an agreement with our group member, processors or other recipients that ensures the use of appropriate and appropriate safeguards. This can be done through mandatory company rules or through standard clauses set by the data protection officer and approved by the European Commission.

11. How Long Will We Store Your Personal Data?

We store your personal data for as long as your account is open. If you don’t have an account, or choose to close your account, we will keep some of your information until 7 years has passed since we last provided product to you. We consider 7 years to be an appropriate retention period because it is as long as is necessary for us to a. respond to any questions, complaints or claims made by you or on your behalf, b. show that we treated you fairly, c. keep records required by regulation or law; and d. satisfy any accounting or reporting requirements.

12. Confidentiality And Security Of Your Personal Data

We aim to keep the Personal Information you provide us secure and we take reasonable precautions to protect it from loss, misuse or tampering.

We implement information security policies, rules and technical measures to protect the personal data under our control from:

• Unauthorized access;
• Improper use or disclosure;
• Unauthorized modification; and
• Unlawful destruction or accidental loss.

All our employees and processors (i.e. those who process your personal data on our behalf for the above purposes) who have access to and are involved in the processing of personal data are obliged to respect the confidentiality of the personal data of all users of the services of to uphold Comvita.

13. Access To Your Data And Other Rights

You have the following rights in relation to your personal data that we have collected about you:

• A. Right to information.
• If you ask us, we will confirm whether we are processing your personal data and, if so, we will provide you with a copy of that personal data (along with certain other information). If you require additional copies, we may charge a reasonable fee.
• B. Right to Rectification.
• If your personal information that we hold is inaccurate or incomplete, you have the right to request its rectification. If we have passed on your personal data to third parties, we will inform them of the correction if possible. Upon your request, we will also, where possible and lawful, tell you with whom we have shared your personal information so that you can contact those third parties directly.
• C. Right to Erasure.
• In certain circumstances you can ask us to delete or remove your personal data, e.g. when we no longer need it or when you withdraw your consent (if applicable). If we have passed on your personal data to third parties, we will inform them of the deletion if possible. Upon your request, we will also, where possible and lawful, tell you with whom we have shared your personal information so that you can contact those third parties directly.
• D. Right to restriction of processing.
• You can ask us to "block" or stop the processing of your personal data in certain circumstances, e.g. if you question the accuracy of this personal data or object to our processing of it. However, this will not prevent us from storing your personal data. We will let you know before we lift a restriction. If we have passed on your personal data to third parties, we will inform them of the restriction if possible. Upon your request, we will also, where possible and lawful, tell you with whom we have shared your personal information so that you can contact those third parties directly.
• E. Right to data portability.
• As of May 25, 2018, you have the right, under certain circumstances, to receive the personal data you have provided (in a structured, commonly used and machine-readable format) and to reuse it elsewhere, or to ask us to transfer it to a third party of your choice.
• F. Right to Object.
• You can ask us to stop processing your personal data and we will do so if we:
• Base the processing of your personal data on our own legitimate interests or those of a third party, unless we can demonstrate compelling legal bases for the processing;
• Use your personal data for direct marketing; or
• Process your personal data for research purposes, unless such processing is necessary for the performance of an activity carried out in the public interest.
• Rights in relation to automated decision-making and profiling.
• You have the right not to be subject to a decision where it is based on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you, unless such profiling is for entering into, or the performance of, a contract required between you and us.
• G. Right to withdraw consent.
• Where the processing of your personal data for certain purposes relies on your consent (or explicit consent) as the legal basis, you have the right to withdraw that consent for those purposes at any time.
• H. Right to lodge a complaint with the supervisory authority.
• If you have any concerns about any aspect of our privacy practices, including how we handle your personal information, you have the right to complain to a data protection supervisory authority about the processing of your personal data by us.

14. Changes To This Data Protection Policy

We may change this data protection policy at any time.

So that you are always aware of how we use your personal information, we will occasionally update this data protection statement to reflect any changes in our use of your personal information. We may also make changes as necessary to adapt to changes in applicable laws or regulatory requirements are. We may notify you of any material changes by email. However, we encourage you to periodically review this data protection statement to stay informed about how we are using your personal information.