1. INTRODUCTION

This is the Privacy Policy  of EURYCA AS -Malvik Norway (hereinafter: “TDW”, “LifThor”,  “we” or “us”). The proper handling of personal data is extremely important to us. We therefore take great care when processing and protecting your personal data. This is done in accordance with provisions set out in the applicable privacy laws (including the General Data Protection Regulation).

To ensure your privacy as far as possible, we adhere to the following core values:

• Information: We wish to inform you about why and how we use your personal data. This is described in this Privacy Policy.
   

• Limited collection: We take great care to limit the information we collect and use to only that which is necessary for selling our Products and/or providing our Services (as defined below).
   

• Security: We take the appropriate measures to secure your personal data and require the same from the parties that use your data on our behalf .TDW proactively tests on a continuous basis its websites and apps by means of an automated security scan.
   

• Individuals’ rights: We respect your rights under applicable privacy laws (including the right to access, correct, or delete your personal data in accordance with such laws).

This Privacy Policy describes how we implement these core values and how we respect and protect your right to privacy. We strongly urge you to read this statement carefully, as it sets out the basis on which we use your personal data when you buy our products online or in one of our stores or via other LifThor points of sale ( “Products” ), access our websites, interact with us or otherwise use our services and applications (jointly referred to as: "Services").

 

2. PERSONAL DATA WE COLLECT AND USE

The personal data we collect about you when you buy our Products or use our Services, include the following (hereinafter jointly referred to as: “Personal Data”):
 

• Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address, and any other contact details you provide to us (including delivery address when you purchase our Products online).
   

• Your electronic identification data and other information we automatically collect when using our online Services. When visiting our websites or apps, interfere (opening, clicking, reading, cursor-movement etc.) with our newsletter or being confronted with online marketing advertisements of TDW, we collect data automatically through your browser or device, by making use of cookies and other technologies to track visitors on the website (including web analytics), such as your IP address, MAC address, your browsing behavior, the Products and Services you like and the content of your abandoned shopping basket. Please see our Cookie Policy to find out more.
   

• Your account data. To complete your account at  we use your name, gender, email address, date of birth and other information you voluntarily provide to us, such as your telephone number
   

• Your purchases online. To complete your online purchases via the official LifThor webs hop or via other official social media-channels of LifThor, we use your name, gender, email address, telephone number (if you voluntarily provide this to us), delivery method and delivery address and all relevant information regarding your purchases, such as the amount and date of your purchases, the Product(s) you purchase, the device through which you make your purchases, payment method, payment status, bank account details, (employee) discount (if any), voucher code used (if any), gift with purchases (if applicable) and optional additional personal card or engraving data. In order to offer you third party partner payment methods, we might pass your personal data in the form of contact and order details to said third parties in the checkout process, in order for them to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with the third party’s privacy notice. Please see this page for our payment partners.
   

• Your personal data when subscribing to our newsletter. To be able to provide you with the newsletter of LifThor containing  new products and commercial content, we use your email address and additional information if you add such to your profile, such as name, date of birth.
   

• Your communication data. Any data shared by you when communicating with us via email, online, telephone, social media or any other form, such as questions, requests or complaints.
   

• Your personal data regarding raffles, subscribe and win, lead generation campaigns, contests or sampling-activation. Any data shared by you when participating in a raffle, subscribe and win, lead generation campaign, contest or sampling-activation.
   

• Your ratings and reviews and feedback. The opinions, experiences, preferences and interests and Product- or event reviews that you publish on our websites or share with us online or through social media.
   

• Health data. We can also collect information in relation to your health, such as regarding your allergies. We will only use health data you voluntarily provide us and such only with your prior consent or under your direction to do so and only for the purposes set out in this Privacy Policy. You may refuse or revoke your consent at any time, as set out below (see ‘Your Rights’).
  
   

3. PURPOSES OF USE PERSONAL DATA

The Personal Data we collect is exclusively used for the following purposes:

For the performance of our agreement with you: In order to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the Products and information that you request, including managing and handling your requests, inquiries or complaints. This also includes enabling you to make a purchase of our Products, to participate in our LifThor program, raffles, contests or our lead generation campaigns, responding to your requests to provide customer service, responding to your inquiries, providing you with essential information regarding our Products you request, etc.

For our legitimate commercial interests:
e use your Personal Data as described above (both on aggregated and on individual basis) for the purpose of advertising our Products and Services, to contact you via e-mail, regular mail, social media or otherwise for direct marketing or other commercial purposes. Furthermore, we use your Personal Data for analysing and improving the quality of our Products and Services, such as providing you with customer services and aftersales, and to understand you as a customer (customer optimization). This enables us to assess what may interest you, to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising. In addition, based on your use of our Services and Products you purchased, we may target you with advertisement or other marketing materials that are customized to your personal preferences and experiences.
 

We may also use your Personal Data, for our other legitimate commercial interests such as to operate and expand our business activities; to develop and improve or modify our Products and Services; to protect and defend our (and others’) rights, property or safety; to prevent abuse and fraud related to online sale of our products and to monitor the compliance with our LifThor House Rules for the use of our website(s); to generate aggregated statistics about the users of our Products and Services; to facilitate our business operations; to operate company policies and procedures; to enable us to make corporate transactions, such as any merger, sale, reorganization, transfer of TDW assets or businesses, acquisition, bankruptcy, or similar event; or for other legitimate business purposes permitted by applicable law.

Use of information based on your consent:
Under circumstances we will also ask your consent for the processing of your personal data. For example, when you have not purchased our Products but would like to receive direct marketing communications (such as newsletters, promotions, news on products) via email, other electronic means. Furthermore, in limited instances, we will process your health data for the purposes set out in this Privacy Policy.

You can withdraw your consent at any time (see the section Your rights below).

To comply with our legal obligations: Any Personal Data we collect may be used to comply with a legal obligation to which we are subject, such as supervisory bodies, fiscal authorities or investigation bodies.

 

4. SOCIAL MEDIA

When you participate in various social media forums like Facebook, Twitter, Pinterest, Instagram, LinkedIn, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the personal data in your social media profile(s).

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TDW is bound by the privacy practices or policies of these third parties, so we encourage you to read the applicable privacy notices, terms of use and related information about how your personal data is used in these social media environments.

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Also, depending on the choices you have made regarding your settings on various social media sites certain personal data may be shared with TDW about your online activities and social media profiles (e.g. interests, marital status, gender, user name, photo, comments and content you have posted/shared etc.).

 

5. SHARING YOUR PERSONAL DATA

We share your Personal Data with the following parties:

• Third Party suppliers. We engage third parties, from time to time, to help us providing us our Products and Services, including:  Business partners, suppliers (such as IT service providers) and sub-contractors;

• Advertising and media companies that carry out marketing and media activities on our behalf (including affiliate marketing);

• Analytics and search engine providers that assist us in the improvement and optimization of our website and apps, such as Google Analytics.

In providing their services, these third party suppliers will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require such Third Party suppliers to adequately safeguard your Personal Data and only process it in accordance with our instructions.
 

• Corporate transaction. In addition, Personal Data may be disclosed as part of any merger, sale or transfer of  LifThor assets.

• Third parties in case of legal requirement. We may also disclose your Personal Data if we believe we are required to do so by law.

• With consent. We may also disclose information about you, including Personal Data to any other third party, where you have consented or requested that we do so, for example in case of a promotional campaign with another sponsor.
  
   

6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Please be informed that TDW may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection to your Personal Data. TDW or Third Party suppliers we use will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer, more in particular for Personal Data transferred to countries outside the European Economic Area. This means that we entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authority where required.

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7. SECURITY

We will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.

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We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Policy. Furthermore, we contractually ensure that any Third Party supplier processing your Personal Data equally provide for confidentiality and integrity of your data in a secure way.

 

8. DATA RETENTION

We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim.

 

9. YOUR RIGHTS

Subject to the conditions set forth in the applicable law, you have the following rights with regard to our processing of your Personal Data:

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• Right of access – You have the right to request confirmation if TDW processes personal data about you, and if such is the case, access to the personal data and additional information. Upon request, we can also provide you with a copy of the personal data undergoing processing;

• Right to rectification – You have the right to request that TDW corrects, adjusts or completes your Personal Data if we have inaccurate or incomplete data relating to you. You can also correct, adjust or complete your personal data yourself by updating your profile.

• Right to withdraw consent – You have the right to revoke your consent for receiving marketing communications at any time, by following the instructions in any marketing communication. If we use your Personal Data based on your consent for other reasons than marketing communication, you can revoke your consent by filling the form as set out below;

• Right to delete - You have the right to request deletion of any irrelevant Personal Data we hold about you when (i) the data is no longer necessary in relation to the purposes for which they are collected; (ii) you withdraw your consent and there is no other legal ground for processing; (iii) you object to the processing in case of direct marketing purposes, or – in any other case – there is no overriding legitimate ground for processing; (iv) we unlawfully processed your data. If you have such a request and all requirements are met, we shall make sure that TDW erases the data of which we are not under a legal obligation to retain;

• Right to restriction of data use - You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but you require them for the establishment, exercise or defense of legal claims; or (iv) you have objected to data use justified on our legitimate interests pending verification as to whether TDW has indeed compelling interests to continue the relevant data use;

• Right to data portability - to the extent that we use your Personal Data for the performance of an agreement with you, and that personal data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to TDW in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible;

• Right to object - to the extent that we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. You also have the right to object to profiling activities conducted by TDW;

• Right to lodge a complaint - You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Policy or applicable law.
  
   

10. CHANGES TO THE POLICY

This Privacy Policy may be revised from time to time. If a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.
 

11. CONTACT US

If you have any queries about this Privacy Policy or our handling of your Personal Data in general, please email us at support@lifthor.com and be sure to indicate the nature of your query.