Privacy policy

Introduction
Purpose of this privacy policy
Who we are
Controller and Contact Us
Changes to the privacy policy and your duty to inform us of changes
Third-party links
The data we collect about you
How is your personal data collected?
How we use your personal data
Purposes for which we will use your personal data
Marketing
Opting out
Cookies
Change of purpose
Disclosures of your personal data
Data retention
Your legal rights
Other important terms

1. Introduction

We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. Purpose of this privacy policy

2.1 Aim. This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you purchase a product.

2.2 Importance. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

3. Who we are

Optibac Probiotics is the trading name of by Wren Laboratories Limited and Medipharma Limited.  Our website is www.optibacprobiotics.com which is operated by Wren Laboratories Limited and Medipharma Limited, both companies are registered in England and Wales.

Throughout this policy we refer to ‘the Company’ and ‘we’ or ‘our’, which means Wren Laboratories Ltd and/or Medipharma Ltd. Wren Laboratories Limited’s company registration number is 5094520 and Medipharma Limited’s company registration number is 2658133 and both companies’ registered office is at 21 & 22 Mayfield Avenue Industrial Park, Andover, Hampshire SP11 8HU. The registered VAT number for both companies is GB 319320031.

4. Controller and Contact Us

4.1 Controller. Wren Laboratories Limited and/or Medipharma Limited is the controller and responsible for your personal data.

4.2 DPO. We have appointed a data protection officer (DPO) who is responsible for overseeing questions, comments and requests in relation to this privacy policy.  Please contact the DPO at privacy@wrenlabs.com or Wren Laboratories, 21 & 22 Mayfield Avenue Industrial Park, Andover, Hampshire SP11 8HU or on Tel: +44 (0) 1264 339 770.

4.3 ICO. 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.

5. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. 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.

6. 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 policy of every website you visit.

7. The data we collect about you

7.1 What is personal data?  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).

7.2 Types of personal data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(i) Identity Data includes first name, last name, username or similar identifier.
(ii) Contact Data includes billing address, delivery address, email address and telephone numbers.
(iii) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
(iv) 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.
(v) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
(vi) Usage Data includes information about how you use our website and products.
(vii) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

8. How is your personal data collected?

We use different methods to collect data from and about you including through:

8.1 Direct interactions. You may give us your Identity, Contact online or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

(i) creating an account on our website;
(ii) ordering our products;
(iii) setting up a subscription for our products or newsletter;
(iv) allowing marketing to be sent to you;
(v) enter a competition, promotion or survey;
(vi) applying for a job with us; or
(vii) giving us reviews, feedback or contacting us.

8.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

8.3 Third parties or publicly available sources. We will receive personal data about you from our payment partners WorldPay and Paypal inside or outside the EU.

9. How we use your 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:

(i) Where we need to perform the contract we are about to enter into or have entered into with you.
(ii) 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.
(iii) Where we need to comply with a legal obligation.

Generally, except as required by law, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 contacting us.

10. Purposes for which we will use your personal data

10.1 We will use your personal data as follows:

(i) To register you as a new customer;
(ii) To process and deliver your order including managing payments, fees and charges and collecting and recovering money owed to us;
(iii) To manage our relationship with you including notifying you about changes to our terms or privacy policy and asking you to leave a review, take a survey or partake in a prize draw or competition;
(iv) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 
(v) To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(vi) To use data analytics to improve our website, products, marketing, customer relationships and experiences
(vii) To make suggestions and recommendations to you about goods or services that may be of interest to you

11. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  You will receive marketing communications from us if you have requested information from us or purchased products from us and you have opted in to receive marketing.  We do not share your details with any third parties for marketing purposes.

12. Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.   Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.

13. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies on our cookies banner or cookies policy, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

14. Change of purpose

14.1 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

14.2 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.

14.3 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.

15. Disclosures of your personal data

We may share your personal data with the parties set out below:

15.1 External Third Parties

(i) Service providers based in the UK, Europe or the US who provide IT and system administration services.
(ii) Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
(iii) HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

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.

15.2 International transfers. Most information we collect about your use of our Website is stored within, and not transferred outside of, the European Economic Area. However data generated by Google Analytics is transmitted to and stored by Google on servers in the United States. Google is certified under the EU-US Privacy Shield.

15.3 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.   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.

16. Data retention

16.1 How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

16.2 How do you 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, regulatory, tax, accounting or other requirements.

16.3 Anonymisation or deletion. In some circumstances we will anonymise your personal data (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. In some circumstances you can ask us to delete your data.  See clause 17.3 for further information.

17. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

17.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

17.2 Request correction of the personal data 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.

17.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data 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 data 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.

17.4 Object to processing of your personal data 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 data 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.

17.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(i) If you want us to establish the data's accuracy.
(ii) Where our use of the data is unlawful but you do not want us to erase it.
(iii) 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.
(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

17.6 Withdraw consent at any time where we are relying on consent to process your personal data. 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. If you wish to exercise any of the rights set out above, please contact us

18. Other important terms

18.1 No fee usually required. You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.

18.2 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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

18.3 Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could 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.