We have developed this Privacy Statement in order for you to understand how Varofoods (“Varo”; “we”) collects or processes your personal data through your use of this website, and which rights you have in relation to the processing of your personal data. We also tell you how you can reach us to answer any questions you may have about data protection. By accessing, browsing, registering, subscribing or otherwise using our website you confirm that you have read, understood and agree to the terms of this Privacy Statement. Please read the Privacy Statement carefully.
WHAT IS A PERSONAL DATA?
Your personal data includes information or a combination of information that could directly or indirectly be used to identify you. Personal data includes an identifier like a name, address, ID number, location data, website usage history, online identifier or to factors about economic, cultural or social identity. Please note, the definition of personal data can vary by region. If we collect information that is considered personal data in your region, we will treat it as such in accordance with this Privacy Statement and applicable local law.
This Privacy Statement is effective as of April 2021. Please note that this Privacy Statement may be updated from time to time reflect any changes in the way we handle your personal data or any changes in applicable laws. We will notify you by updating this page.
WHICH CATEGORIES OF PERSONAL DATA DO WE COLLECT AND HOW DO WE PROCESS SUCH PERSONAL DATA?
We may collect personal data of our customers, suppliers and website users and individuals who interested in Varo and interact with Varo.
Below also describes the categories of personal data we may collect:
Personal details, identifiers – Identifiers are things like your name, e-mail and other contact information. We also collect the contact details you provide us when corresponding with us, information that you provide to Varo when you sign up to varofoods.com newsletter and any information that you provide voluntarily when you provide answers to our surveys. We use these to provide services, personalised content, information; to improve the features; to communicate with you upon your request and to send you brochures, coupons, samples, offers and other information on our products.
Usage data and Device Information – We get Internet Protocol (IP) address, device identifier, device’s operating system, time zone setting and location directly from you (e.g., if you allow location services such geolocation data from observing your region) and your activities on our website, as well as interaction with advertisements indirectly through third party analytic providers such as [Google Analytics, etc.] We use these to provide you with personalized content, information, and to send you brochures, coupons, samples, offers and other information on our products; and/or to deliver relevant advertising.
Information collected from our website and social media pages – This includes information collected when you interact with us. For example, comments, feedback, reviews, photos, or other information that you post through blogs, message boards, or social networking.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect personal data through our website in two ways: (1) direct interactions (for example, when you provide personal data to sign up for a newsletter); and (2) automated technologies (for example, through our website’s technology). Direct interactions: This includes the personal data that you provide by filling in forms on our website or by corresponding us by post, phone, email or otherwise. This includes filling surveys, subscribing to services, newsletters and alerts. It is completely at your discretion to provide such personal data to us. If you contact us, we may keep a record of that correspondence. Automated technologies: As you interact with our website, we will automatically collect technical data about your device, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics. We may also collect the details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data and other usage and communication data. For further information, we also encourage you to see our Cookies Policy to find out more about how we collect usage data. We may also receive technical data from analytics providers such as Google etc.
FOR WHICH PURPOSES AND ON WHICH LEGAL BASIS DO WE USE YOUR PERSONAL DATA?
Please view the table below for (i) a list of the purposes for which Varo uses your personal data and (ii) an overview of the legal basis for each such purpose. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below. We may use your personal data we collect to fulfil your requests for, and enable your use of, our features, products and services – justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business. We may use your personal data to communicate with you, to respond to your questions or comments or to provide you with updates and news -justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business. We may use your personal data to deliver relevant advertising. This way, users will see advertising that is most likely to interest them. You will be required to “opt-in” before we can contact you in certain ways or before certain services become available. We honor opt-out requests. We may use your personal data to send you brochures, coupons, samples, surveys, feedback requests, offers and other information on our products – justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business and provide you with excellent user experience.
Recruitment – justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees who have applied through our website, varofoods.com.
Operating and managing our business operations – justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements. Necessary for the compliance with a legal obligation to which we are subject. Monitoring your use of our website – justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Social listening (Identifying and assessing what is being said about Varo on social media (only publicly accessible content) to understand sentiment, intent and market trends. We regularly do this to gain insights, not to identify an individual – justified on the basis of our legitimate interest of protecting our assets and our brand on social media.
Improving the security and functioning of our website, networks and information – justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Varo and/or to provide a better user experience – justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to the Privacy Statement, doing so will be considered as providing your consent Varo to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.
WHAT ABOUT SENSITIVE DATA?
We do not generally seek to collect sensitive personal data (also known as special categories). However, we do sometimes collect sensitive personal data through our website when you contact us and provide health related information such as allergies or other health conditions which may affect your diet. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your prior consent.
WILL YOU RECEIVE TARGETED MARKETING E-MAILS?
We may send personalized commercial e-mails to our customers with whom we want to develop or maintain a customer relationship in accordance with applicable laws. We also may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you to understand your needs and preferences.
Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Varo, we may also use a cookie to log what pages you view and what content you download from our website. You can ask us to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences by following the opt-out links on any marketing message sent to you or by contacting us at any time.
WILL WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
We generally do not share your personal data with third parties. However, we may need to share your personal data time to time with partners, agents, professional advisors, and affiliates to allow them to perform services on our behalf or public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. When we share your personal data with third parties, they are strictly controlled in how they may/may not use your data and we remain responsible for the protection of your data. The third parties we may share the personal data include:
If you enter a promotion where we have a collaboration with a third party, If we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your data may be one of the transferred assets and we will notify you that such transfers may occur and are permitted by this Privacy Statement, If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Varo, our customers, or others.
To deliver services to you, it is sometimes necessary to share your personal information other countries from time to time. This may include all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’) on the basis of an adequacy decision. In the absence of an adequacy decision or appropriate safeguards outside of the EEA, we will ensure that the transfer will be compliant with data protection law of the destination country and all personal data will be secure.
WHAT ABOUT 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 competent supervisory authority where we are legally required to do so.
HOW LONG WILL YOUR PERSONAL DATA BE RETAINED BY US?
We will retain your personal data only for as long as is necessary for the relevant purpose for which it was collected. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
We retain your data as long as we have an ongoing relationship with you (e.g., opt-in to marketing). We retain your data for as long as needed in order to comply with our global legal and contractual obligations. We will take all reasonable steps to destroy or de-identify personal data we hold if it is no longer needed for the purpose for which it was collected.
WHICH RIGHTS DO YOU HAVE WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA?
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to: Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data. Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
Object to the processing of your personal data: this right entitles you to request that Varo no longer processes your personal data. Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
Obtain from us without undue delay the rectification of inaccurate personal data concerning you. Receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
If you have any questions in relation to your rights or to exercise your rights please contact us from firstname.lastname@example.org. If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, you have the right to make a complaint at any time to the relevant supervisory authority in your region, however, we encourage and welcome individuals to come to Varo first to seek resolution of any complaint.
DO WE INCLUDE (LINKS TO) WEBSITES AND PROGRAMS OF THIRD PARTIES?
Third party links will take you to a third party website, owned and operated by an independent party over which we have no control (“3rd Party Website”). Any use of the 3rd Party Website will be subject to and any information you provide will be governed by the terms of the 3rd Party Website, including those relating to confidentiality, data privacy and security. As we have no control over 3rd Party Websites, we shall not be in any way associated with the owner or operator of the 3rd Party Website or responsible or liable for the goods and services offered by them. We encourage you to read their Privacy Statements once you visit a 3rd Party Website.
You can contact us by email from email@example.com if you have any questions about this Privacy Statement, or the information we hold about you or if have a general question about how Varo protects your personal data.