Privacy Policy

INTRODUCTION 

Welcome to Oro’s privacy notice.

Oro, owned by Holland & Barrett Ltd, respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information when you:

  • visit our website (regardless of where you visit it from) www.weareoro.com

  • use our mobile app ‘Oro’

and tell you about your privacy rights and how the law protects you.

 

PURPOSE OF THIS PRIVACY NOTICE 

This privacy notice aims to give you information on how Oro (Holland & Barrett) collects and processes your personal information through your use of our website or our mobile app.

Our website and app are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

CONTROLLER 

Holland & Barrett Retail Limited

Holland & Barrett Retail Limited is the controller and responsible for your personal information (collectively referred to as ”Holland & Barrett”, “we”, “us” or “our” in this privacy notice).

Holland & Barrett is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Holland & Barrett Group so when we mention ”Holland & Barrett”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Holland & Barrett Group responsible for processing your data and include their terrestrial stores and the Website.  Holland & Barrett Retail Limited is the controller and responsible for this app.

We have colleagues who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the relevant team using the details set out below. If you would like to exercise any of your legal rights please complete the relevant form included at the Your legal rights section of this privacy notice and send this to us at the details included on the form.  Our team will be happy to help with any questions that you may have.

 

CONTACT DETAILS 

Our full details are:

Legal entity: Holland & Barrett Retail Limited

Contact: Oro Team

Email address: customerservice@weareoro.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 

This version was last updated on 18th May 2020.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You can update your information at any time by amending your personal information within ‘Settings’ section of the Oro app.

 

THIRD-PARTY LINKS 

The app and website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our app or website, we encourage you to read the privacy notice of every website you visit.

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).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, gender, date of birth, email address.

  • Contact Data includes billing address, email address and telephone number.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical 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, cookie ID’s, web log information, device identifiers and other technology on the devices you use to access this website.

  • Profile Data includes your username and password, preferences and feedback.

  • Usage Data includes information about how you use our app, your activity including purchases, connection information and statistics on your visits to site and page views, the links you click and other actions you take on our app, website, within our advertising or e-mail content and participation in promotional activity. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Special Categories of Personal Information includes information about your health and physical condition. 

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 information but is not considered personal information 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 app feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

Unless you are a Healthbox user, we do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The nature of the Oro app means that we process some Special Categories of Personal Information about you based on the confidential information which you provide to Oro (Holland & Barrett) for this purpose. We process this information which you have provided to us with your consent only for the purpose of providing the Oro service to you.  Special Categories of Personal Information which may be processed about you as part of Oro include details about your race or ethnicity, philosophical beliefs, sex life and information about your health.

 

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION 

Where we need to collect personal information 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 goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into 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.

  • Where we need to comply with a legal or regulatory obligation.

Please see point 5 below (Purposes for which we will use your personal information) to find out more about the types of lawful basis that we will rely on to process your personal information.

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by accessing your account “Settings”, or by e-mailing or contacting our Customer Services team.

customerservice@weareoro.com

 

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

In general terms, we use the personal information we collect to help Oro better understand you and to enable us to personalise your experience with Oro, including offers, promotions and services to meet your needs. We use your information to:

  • personalise our services, offers and promotions to you and provide you with a personalised experience on our app and website;

  • operate your account;

  • offer you site content;

  • contact you about your account and tell you about important changes to Oro (Holland & Barrett);

  • provide, develop and improve our products and services;

  • provide you customer service;

  • manage promotions, competitions, customer surveys and questionnaires; and

  • check and verify your identity, and prevent, mitigate or detect and investigate crime, fraudulent or illegal activities;

  • process purchases, payments and customer support.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below you can request this information by emailing your request for this information to

customerservice@weareoro.com

 

 

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

(c) Special Categories of Personal information

(a) Performance of a contract with you

(b) Consent

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to prevent, detect, mitigate and investigate fraudulent or illegal activities

(a) Identity

(b) Contact

(c) Technical

(d) Financial

(e) Usage

(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)

(b) Necessary to comply with a legal obligation

To deliver relevant app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Special Categories of Personal information

(a) Necessary for our legitimate interests (to develop our products/services and grow our business);

 

(b) In limited circumstances we rely on consent (see marketing communications from us below)

 

(c) Consent

 

MARKETING 

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You can view and make certain decisions about your personal information use at any time at your account, or by e-mailing or contacting our Customer Services team.

In summary:

  • amend your options within the ‘Settings" section on the App;

  • click on the "unsubscribe" link on the bottom of any of our e-mails to opt of email communications;

  • Email us on customerservice@weareoro.com

 

PROMOTIONAL OFFERS FROM US 

We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).

 

MARKETING COMMUNICATIONS FROM US

In general, you will receive marketing communications from us by email, SMS or social media if you have requested information from us or purchased goods or services 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.

Oro is committed to transitioning over time the basis of its e-mail marketing communications to customer consent. To achieve this we will be gradually transitioning our lawful basis for processing to consent and will do this in a number of ways and over a period of time depending on how you engage with us, and whether you are new to Oro and Holland & Barrett or an existing customer or user of Holland & Barrett products or services.

If you have any questions about how we are lawfully processing your information you can request this information by e-mailing your request for this information to customerservice@weareoro.com

 

 

THIRD-PARTY MARKETING 

We will get your express opt-in consent before we share your personal information with any company outside the Holland & Barrett group of companies for marketing purposes.

 

 

THE RIGHT TO OBJECT TO PROFILING

Where we process personal information relating to your interaction (transactions, site visits, app usage) with Oro to enable us to personalise your experience with the Oro app. This processing activity constitutes profiling under the GDPR and we process your personal information in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.

You have the right to object to how your personal information is processed including your right to object to profiling as outlined in this privacy policy.  More information on this right to object and how to exercise your rights can be found in section 10. Your Legal Rights below.

We do see profiling as a beneficial service allowing you to have easier and quicker access to products, services and offers tailored more specifically to your interests, but we respect that not everyone feels the same way and we will be sad to see you go. 

 

 

CHANGE OF PURPOSE 

We will only use your personal information 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 on customerservice@weareoro.com

 

If we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary below.

  • External Third Parties as set out in the Glossary below.

  • 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 information in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Please contact customerservice@weareoro.com if you want further information on the third parties we use.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.

Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact customerservice@weareoro.com if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR? 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  In addition, this includes that we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies

When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure in section 10. Your Legal Rights below for further information.

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please see below to find out more about these rights and access the request forms should you want to make any of these requests:

If you wish to exercise any of the rights set out above, please send the completed forms to us to the e-mail or postal address included on the form.

 

NO FEE USUALLY REQUIRED 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

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.

You have the right to:

Request access to your personal information (commonly known as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you want to receive a copy of any information we process about you please complete the request form and send to our team at  customerservice@weareoro.com

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You can update First Name, Last Name, Email Address and Password at any time within the App. To change other details, you will need to email customerservice@weareoro.com. Please note, these changes are not able to update your current plan.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You can request erasure of your information at any time by emailing customerservice@weareoro.com.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You can update your Marketing preferences at any time in the App or emailing customerservice@weareoro.com.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. You can request restriction of processing any time by emailing customerservice@weareoro.com.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. You can request the transfer of your personal information any time by emailing customerservice@weareoro.com

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent at any time by emailing customerservice@weareoro.com

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