Privacy Policy

1. INTRODUCTION

This privacy policy tells you how the DR.VEGAN group of companies uses your personal data when you visit our website or interact with us, including when you sign up to our newsletter, use our products and services or take part in a competition.

It also tells you your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your personal data.

CHILDREN

This website is not intended for children under 16 and we do not knowingly collect data relating to children. This privacy policy was last updated on 26 March 2024.

If you have any questions, please contact us at team@drvegan.com.

HOW TO CONTACT US

If you wish to contact us about our Privacy Policy, or regarding any data we may have about you, please contact us by email at team@drvegan.com.

2. DESCRIBING WHO WE ARE

DR.VEGAN’s mission is to create the most efficacious plant-based supplements, developed by practitioners, using only sustainably sourced ingredients, with zero nasty additives, in order for you to achieve your health goals.

DR.VEGAN is the data controller responsible for this website and responsible for the personal data we collect from you. Being the data controller means we are responsible for deciding why and how we use personal data in our business. DR.VEGAN and its group of companies work collaboratively to provide its products and services to customers all over the world and may sometimes be acting as joint data controllers.

The DR.VEGAN group of companies includes DR.VEGAN Limited (DR.VEGAN UK) and DR.VEGAN Inc (DR.VEGAN US). When we mention DR.VEGAN, “we”, “us” or “our” in this privacy policy, we are referring to DR.VEGAN Limited.

We have appointed a Data Protection Officer who is responsible for looking after questions about this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please see contact us at team@drvegan.com.

3. HOW WE COLLECT DATA

There are lots of different ways in which we may collect data, or receive data, and you can see an explanation of the main ways below.

You may give us data when you interact with us.

You may give us data by filling in forms or by corresponding with us by post, phone, email or through chat or social media. This includes data you provide when you:

• sign up to receive our newsletter;
• make enquiries or request information be sent to you;
• create an account on our website;
• order our products;
• ask for direct marketing to be sent to you;
• use ‘refer a friend’;
• engage with us on social media;
• enter a competition, promotion or survey;
• contact customer services; or
• leave comments or reviews on our products or services.

We may get some data automatically.

As you interact with us, including via the DR.VEGAN website, we may automatically collect data about your equipment, browsing actions and patterns. We may also collect data when you click on one of our adverts (including those shown on third party websites or via social media).

We may obtain some data from third parties.

We may receive data about you from various categories of third parties, including:

• from providers of services which facilitate our ecommerce operations, including ecommerce platforms and payment and fraud prevention services;
• from analytics providers, advertising networks and search information providers;
• from data partners;
• from your friends who referred you using ‘refer a friend’;
• from publicly available sources; and
• from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

If you submit any data about another individual to us, you are responsible for making sure that you have the authority to do so and allow us to use their data in accordance with this privacy policy.

4. TYPES OF PERSONAL DATA WE MAY COLLECT

Above we described all the different methods in which we collect data, to be given or obtain data. Some of that data may be personal data and we explain below the types of personal data we may collect about you. The types of personal data we collect about you will depend on how you are interacting with us.

Personal data, or personal information, means any information about an individual from which that person can be identified and which we maintain in accessible form. It does not include data where the identity has been removed (anonymous data).

We collect a variety of personal data about our customers and visitors to the DR.VEGAN website.

This personal data falls into these categories:

• Identity Data includes title, gender, first name, last name, date of birth, username or similar identifier and your login/password. If you interact with us through social media, this may include your social media username.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card and direct debit/bank account details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or other DR.VEGAN retailers.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
• 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 and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services, and any of the content you contribute to the forum.
• Tracking Data includes information we or others on our behalf collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
• Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

Please note that we may collect further categories of personal data if you choose to participate in research surveys and through our Diet Profile (also known as ‘Health Check’). These further categories of personal data may include: diet and eating habits, fitness/lifestyle information, and beliefs. We use this information to better tailor our communications to you as an individual.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users following a particular type of diet.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (except if you choose to participate in research and answer the relevant questions (which are non-mandatory)). This may include 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. We do not collect any information about criminal convictions and offences. If you post any of this data on the forum, you have chosen to make it public online, and anyone can read it.

If you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

5. THE LEGAL BASES FOR USING PERSONAL DATA

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

• Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, this is a contract between you and us for us to supply the products to 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. For example, fraud screening as part of the check-out process or keeping our website secure.
• Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

See 'How and why we use your personal data' below for more detailed information.

6. HOW AND WHY WE USE PERSONAL DATA

The table below gives a breakdown of the details of how we are using your personal data, the types of personal data that applies to and why it is we can do this. When we explain why, we will identify the relevant category explaining the legal bases for using personal data above, and, where it’s based on being able to do so for our legitimate interests, we will highlight what that legitimate interest is.

We may process your personal data for more than one legal basis depending on how we are using it.

How we are using the personal data	What types of personal data do we use to do that	Why it is that we can do that
To register you as a new customer	Identity, Contact	Performance of a contract with you
To manage a potential sale with you, including letting you know you have left products in your basket without checking out	Identity, Contact Financial, Transaction, Marketing and Communications	Necessary for our legitimate interests (including being able to progress purchases of products by our customers)
To process and deliver your order including manage payments and collect and recover money owed to us	Identity, Contact Financial, Transaction, Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (including to recover debts due to us)
To manage our relationship with you, including notifying you about changes to our terms or privacy policy	Identity, Contact, Profile, Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To ask you to leave a review or take a survey	Identity, Contact, Profile, Marketing and Communications   Further data categories for surveys, Diet Profile and Health Check - see section 4	Necessary for our legitimate interests (to study how customers use our products/services)   Consent (we collect your consent before you submit your answers to the DR.VEGAN surveys)
To enable you to take part in a prize draw or competition	Identity, Contact, Profile, Usage, Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To deliver direct marketing to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Tracking	Necessary for our legitimate interests (to promote our own business and our products and services), unless the law requires that the direct marketing be based on consent Consent, before we share your personal data with any company outside the DR.VEGAN group of companies for their own marketing purposes
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact, Technical, Tracking	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we have on our website	Identity, Contact, Profile, Usage, Marketing and Communications, Technical Tracking	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 deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical Tracking	Necessary for our legitimate interests (to promote our business and products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical, Usage, Transaction, Profile	Necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business and to inform our product and marketing strategy)
To make suggestions and recommendations to you about products/services that may be of interest to you	Identity, Contact, Technical, Usage, Profile, Transaction	Necessary for our legitimate interests (to develop our products/services and grow our business)
To prevent and detect unlawful acts	Identity, Contact, Financial, Transaction, Technical, Tracking	Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring) Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement
To administer our business and keep proper records	All relevant data categories	Necessary to comply with a legal obligation Necessary for our legitimate interests (to administer our business and keep proper records)
In order to resolve legal claims or disputes involving you or us	All relevant data categories, depending on the nature of the allegation or claim	Necessary for our legitimate interests (to bring or defend a claim, whether in court proceedings or in an administrative or out of court settlement, for the protection or assertion of our legal rights, your legal rights or the legal rights of others)

 

7. ADVERTISING, MARKETING AND YOUR COMMUNICATION PREFERENCES

DR.VEGAN conducts lots of different types of advertising, and these may not be using your personal data. If you see DR.VEGAN’s adverts on websites and in social media, these may not be directed specifically at you. We may also be using a ‘lookalike’ features in search engine or social media platforms, which are not directed at you and which you can control using each search engine or social media platform’s privacy settings.

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of 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 and tell you about them. We may carry out direct marketing by email, phone, text and post.

On our website, we make your direct marketing preferences clear. You may choose to opt in to receive our newsletter, or as part of creating an account. We may also be able to send our customers relevant direct marketing about our own products and services unless they opted out during the purchase journey. We may also send you a little nudge as part of the purchase if you have left products in the basket without checking out.

At all times you have a right to opt out of direct marketing. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication or just email us at team@drvegan.com.

We will get your express opt-in consent before we share your personal data with any company outside the DR.VEGAN group of companies for direct marketing purposes.

We also work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including on websites and in social media.

Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new DR.VEGAN customers. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you’ve been on the DR.VEGAN website, you might see content from our website again. This is called retargeting.

Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third-party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the European Interactive Digital Advertising Alliance and, for the United States, the Digital Advertising Alliance and the Network Advertising Initiative. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative's Mobile Choices page. We do not control cookies which are set by advertising networks.

When you visit or log in to our website; cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses.

8. COOKIES

A cookie is a small file of letters and numbers that we store via your browser.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

We use the following categories of cookies:

• Strictly necessary cookies. These are cookies which are needed to make the website work properly. They include, for example, cookies that enable you to log in, use a shopping cart or make secure payments.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). These also allow us to tell if you’ve left any products in your basket without checking out.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website relevant to your interests and for advertising and retargeting purposes. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You may opt out of cookies set by specific entities by following instructions found at these links:

• Adobe: https://www.adobe.com/privacy/opt-out.html
• Google: https://adssettings.google.com/authenticated
• Facebook: https://www.facebook.com/about/ads
• LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
• Microsoft: https://account.microsoft.com/privacy/ad-settings/signedout
• Twitter: https://twitter.com/settings/account/personalization
• Yahoo: https://policies.yahoo.com/xa/en/yahoo/privacy/topics/opt-outfaq/

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. For further information about how to block cookies, please refer to your browser ‘help’ section or All About Cookies.

Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use. 

Please be aware that if you delete your cookies, we will no longer know that you've opted out of online behavioural advertising, so our adverts will still appear to you on other websites. In addition, we will no longer automatically recognise any website preferences that you have set.

9. DISCLOSURES OF YOUR PERSONAL DATA

We may share personal data within the DR.VEGAN group of companies.

We may share personal data with the following categories of third parties for the purposes set out in this privacy policy:

• Suppliers and service providers which process personal data on our behalf including technology service providers, logistics providers, post and courier service providers, data partners, auditors and professional advisors such as bankers, lawyers, accountants and insurers.
• Government departments and agencies, regulators, and law enforcement where we are required to share personal data by law.

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

We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about how cookies are used in relation to third parties.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

10. DATA SECURITY

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

However, no security measure of modality of data transmission over the internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

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

11. DATA RETENTION

We will only retain your personal data 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal 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. We also keep this basic information about our customers for a maximum of seven years following your most recent purchase from us, or to enable us to deal efficiently with any after-sales queries that you may have. We keep customer profile information that you have indicated you are happy for us to have in order to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data, or for seven years following your most recent active interaction with us (e.g. opening or clicking on an email we send you), whichever of these two is shorter.

12. HOW TO CONTACT US ABOUT PRIVACY

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at team@drvegan.com or write to us with your letter addressed to: Data Protection Officer, DR.VEGAN Limited, Crispins, Manor Farm Lane, Michelmersh, Romsey, SO51 0NT, UK.

If you need help about our products and services, or this website generally, please contact us here.

13. THIRD PARTY LINKS

This 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 website, we encourage you to read the privacy notice of every website you visit.

14. "DO NOT TRACK" SIGNALS

Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. As yet, there is not a uniform way that browsers communicate the "Do Not Track" signal, so the Sites may not currently interpret, respond to or alter their practices when they receive "Do Not Track" signals.

15. WHAT IF YOU DON’T PROVIDE DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us and we will notify you if this is the case at the time.

16. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If 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.

17. LEGAL RIGHTS OF NEVADA RESIDENTS

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to team@drvegan.com

18. LEGAL RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the privacy policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this Notice to California residents section we will refer to this information as “Personal Information.”

• Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

1. Specific pieces of Personal Information that we have collected about you;
2. Categories of Personal Information that we have collected about you;
3. Categories of sources from which the Personal Information was collected;
4. Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
5. Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

You may submit a request to know by emailing team@drvegan.com or calling (+1) 628-250-7715

COLLECTION OF PERSONAL INFORMATION

We currently collect the following categories of Personal Information about California residents directly from them and from advertising networks, internet service providers, data analytics providers, operating systems and platforms (including Shopify), and social networks:

• Identifiers (name, alias, postal address, online identifier, internet protocol address, email address, account name)
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Telephone number
• Internet or other electronic network activity information (browsing history; search history; and information regarding consumer's interaction with website, application or advertisement)
• Geolocation data
• Commercial information (records of products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies)
• Gender
• Audio (customer service recorded calls)
• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

In addition to the purposes stated above in ‘How and why we use your personal data’, we currently collect, and have collected, the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business
• Advancing a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

DISCLOSURE OF PERSONAL INFORMATION

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the date this privacy policy was last updated and, for each category, the category of third parties to whom the Personal Information was disclosed. We did not sell Personal Information to third parties in the 12 months preceding the date this privacy policy was last updated.

Category of Personal Information	Category of third parties to whom information was disclosed
Identifiers (name, alias, account name, email address, postal address); Unique personal identifiers (customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) telephone number; Internet or other electronic network activity information (information regarding consumer's interaction with website, application or advertisement); Geolocation data; Commercial information (records of products or services purchased, obtained or considered)	Email service provider, ecommerce platform, customer service provider, data storage provider, referral messaging provider, customer review provider, fulfilment and logistics providers, financial ERP provider
Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology	Email service provider, ecommerce platform, customer service provider, data storage provider, referral messaging provider, customer review provider, fulfilment and logistics providers, financial ERP provider, data analytics provider, advertising networks (with your consent)

 

We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

• Right to Request Deletion of Personal Information

You have the right to request that we delete the Personal Information we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

You may submit a request to delete by emailing team@drvegan.com

• Right to Opt-Out of Sale of Personal Information

You have the right to direct a business to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.

• Right to Non-Discrimination for the Exercise of Your CCPA Rights

We will not discriminate against you if you exercise any of the rights provide in the CCPA as described above. As such, we will not deny goods or services to you; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

PROCESS FOR VERIFYING A CCPA REQUEST

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

AUTHORIZED AGENTS

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

SHINE THE LIGHT LAW

We do not disclose personal information obtained through our website to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

ERASURE LAW

If you are a California resident under the age of 18, California Business & Professions Code § 22581 permits you to request and obtain removal of any content or information posted on a publicly available forum hosted or provided by DR.VEGAN. DR.VEGAN does not current use or operate any public forums. If you believe we do, and wish to make a request, please contact us at team@drvegan.com.

19. ACCESSIBILITY

We are committed to ensuring this privacy policy is accessible to individuals with disabilities. If you wish to access this privacy policy in an alternative format, please contact us at team@drvegan.com.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

© DR.VEGAN Limited 2023