Privacy Policy

Ceuta Healthcare Limited (“Ceuta,” “we,” “us,” and “our”) has been appointed by Blistex Inc. (“Blistex”) to act as its agent in the UK, to market Blistex’s Odor-Eaters range of products (“Products”) and to answer and investigate any queries and complaints regarding the Products within the United Kingdom.

We understand that privacy is important to you (“you” and “your”) as the user of the Products. This privacy policy (“Policy”) sets out the basis on which any personal information we collect from you, or that you provide to us, through [http://www.odor-eaters.co.uk/] (the “Site”), which is owned by Blistex and operated by Ceuta on Blistex’s behalf.

It is important that you read this Policy together with any other privacy policy or fair processing policy 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. By using the Site, you agree to the collection, use and sharing of your personal information as set forth in this Policy.

What Information We Collect

We do not collect personal information about you unless you voluntarily submit that information to us via the Site or by contacting us by phone or mail. The personal information which you may provide to us could include:

Your name and, if different, the name of the user of the Products
Your contact information including your email address, postal address and telephone number
Your age and gender
Details of any adverse event, enquiry or complaint relating to the Products
Communications data, for example any information which you choose to provide to us when you communicate with us or receive customer support
Device and technical data, such as your browser type, operating system, and your IP address (a unique address that identifies your computer on the Internet)
Marketing data, including your preferences in receiving marketing from us and our any relevant third parties to which you have expressly consented, and your engagement with our marketing communications
Details of the Products used and any other products used at the same time

How We Collect Information

We collect personal information:

directly from you (for example, when you contact us via the Site or when you provide information to us either by phone, email or mail)
through automated technologies and interactions, e.g. via cookies (for example, as you interact with and use our Site)
from third party marketing analytics service providers, website analysis firms, or search information providers, such as data aggregators

How We Use Your Information

We use the information we collect through the Site in the following ways:

to provide the information, products and services you request;
to efficiently respond to your questions, enquiries or complaints;
to provide you with effective customer service;
to provide you with a personalized experience when you use the Site;
to contact you with information and notices related to your use of the Products and the Site;
to improve the content, functionality and usability of the Site;
to better understand your needs and interests;
to represent Blistex in relation to the Products in the UK and allow Blistex to improve the Products;
to improve our marketing and promotional efforts;
to share with others as described in this Policy;
in accordance with your consent; and
for any other purpose identified in an applicable Privacy Notice, click-through agreement or other agreement between you and us.

Legal Bases for Processing Your Data

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

Where it is necessary for our legitimate interests (or those of a third party (for example) Blistex)) and your interests and fundamental rights do not override those interests, which include growing our business, efficiently dealing with customer complaints and enquiries, efficiently fulfilling our legal and contractual duties and managing legal risk, providing high-quality customer service, and keeping you informed (including marketing).
Where we need to comply with a legal obligation, such as to record all safety or quality issues for monitoring purposes of the Products and to report safety and quality issues relating to the Products to the relevant regulator or authority.
Where you have provided your consent (see “Marketing” below).

Marketing

In relation to marketing communications, we will provide you with an “opt in” or “opt out” mechanism depending on where you are located when we collect your personal information. An “opt in” mechanism will provide you the opportunity to positively indicate that you would like to receive our marketing communications and we will not send you any unless you have “opted in”. An “opt out” mechanism (e.g., “unsubscribe”) will provide you the opportunity to indicate that you do not want us to send you such communications, and if you “opt out” we will not send you any.

You may opt out of marketing-related emails by clicking on a link at the bottom of each such email, or by contacting us using the contact details above. You may continue to receive service-related and other non-marketing emails. We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.

How We Share Your Information

With Blistex

Ceuta shares your personal information with Blistex and its subsidiaries, to enable Blistex to efficiently deal with your enquiries, question or complains and to effectively manage the marketing and sale of the Products in the UK market, e.g. to manage product recalls.

With Third-Party Vendors

Ceuta shares information collected through the Site with third-party vendors who act for us or on our behalf. For example, we may use third-party service providers (“Service Providers”) to design and operate the Site, or to develop software applications and databases; to conduct surveys; and to help us with our promotional efforts. These Service Providers may need may have access to your personal and anonymous information in order to perform these functions on our behalf. These Service Providers may also contact you or send communications on our behalf, including, without limitation, in connection with market research studies about our products or our competitors’ products.

As Part of a Business Transfer

Your information may be transferred to a successor organization if, for example, we transfer the ownership or operation of the Site to another organization or if we merge with another organization. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply with Laws and Protect Our Rights and the Rights of Others

We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law or a court order. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of the Site; to enforce or apply our Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We also reserve the right to disclose your information as described in any click-through agreement to which you have agreed.

Information About Third-Party Cookies and Interest-Based Advertising

On our Site, we collect information using “cookies.” Cookies are small data files stored on your device. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on our Site. We only use first-party cookies, served directly by us to your device, which we use to recognize your device when it revisits our Site. You can find more information about cookies and how to manage them at www.allaboutcookies.org.

TYPE OF COOKIE	PURPOSE
Essential Cookies	These cookies are essential to provide you with services available through our Site and to enable you to use some of their features. Without these cookies, the services that you request via our Services may not be possible to provide. We only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personalized experience and to avoid you from having to re-select your preferences every time you use our Site.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather demographic information and to monitor the level of activity on our Services.

You can typically remove or reject cookies via your browser settings. To do this, follow the instructions provided in your browser (usually located within the “settings,” “help,” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your device.

Your Rights

Under certain circumstances, you have the following rights in relation to the personal information we hold about you, unless provided otherwise by relevant local legislation:

Request access to your personal information
Request correction of your personal information
Request erasure of your personal information
Object to processing of your personal information
Request restriction of processing your personal information
Request transfer of your personal information
Right to withdraw consent (where we rely on your consent as our basis for processing)

You can exercise any of these rights by contacting us using the contact details provided above.

Please note that some of these rights are not absolute and we may refuse a request to exercise particular rights, but we will keep you informed as to the actions that we can take when you make your request.

You also have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.

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. 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). Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month.

Links to Other Websites

Our Site may link to third-party websites or advertisers. These third-party websites or advertisers may collect certain personal and non-personal information, including, product usage data, and general location based information. These third-party sites or advertisers may share information they collect about you with us but we are not responsible for their data collection practices.

We are not responsible for the privacy practices of other websites. We encourage users to read the privacy statements of other websites that collect personal information. This Policy applies only to information collected by Ceuta via the Site.

How We Protect Your Information

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 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. All information you provide to us is stored on our secure servers.

International Transfers

Where our service providers or other third parties (identified above) based outside the European Economic Area receive personal information, we ensure the transfer is either (a) to a country deemed to provide an adequate level of protection by the European Commission, (b) pursuant to specific contracts approved by the European Commission, or (c) for transfers to the US, pursuant to that third party’s certification to the Privacy Shield. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA or Switzerland.

Blistex is based in the United States and so information may be transferred to and accessed by Blistex personnel in the United States. By using the Site, you consent to the processing, transfer and storage of your information in and to the United States and other countries, where you may not have the same rights as you do under your local law.

Retention of Personal Information

We only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements. This may mean that for product safety notifications, we may have to retain your personal information indefinitely, but most other personal information is kept for no longer than 6 years.

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

Child Privacy

We do not knowingly collect personal information from anyone under the age of 16. If you are a parent or guardian and become aware that your child has provided us with personal information without your consent, please contact us using the contact details above.

Changes To Our Privacy Policy

We may update this Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Policy on Site for a reasonable period prior to implementing the changes, and we will indicate the date these terms were last revised at the top of the Policy. Any revisions to this Policy will become effective on the date stated in the notice.

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