Kenko Health Privacy Policy

Effective as of: 2025

This is the privacy policy of Kenko Health Ltd trading as Kenko Health.
Kenko Health Ltd is registered in Ireland under company number 784912 with a registered office at Tomcoole Barntown, Wexford, Y35FT52, Ireland.
Kenko Health respects your privacy and is committed to protecting your personal data. This policy will inform you how we look after your personal data when you visit our website www.kenko-health.com and about your privacy rights and how the law protects you.

1. KEY DEFINITIONS
   1. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
   2. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
   3. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
2. IMPORTANT INFORMATION AND WHO WE ARE
   1. Purpose of this privacy policy: This policy aims to give you information on how Kenko Health collects and processes your personal data through your use of this website, including any data you may provide when you purchase a product or service. It supplements other notices and privacy policies and is not intended to override them.
   2. Controller: Kenko Health ("we", "us") is the controller and responsible for your personal data.
   3. Contact Details:
      Data Protection Officer: Fabrizio Marini
      Email: fabrizio@kenko-health.com
      Tel: 0876060476
      Address: Data Protection Officer, Unit 3 Berry Sports Medicine Centre, Adamstown, Enniscorthy, Co. Wexford, Y21A0K8, Ireland.
   4. You have the right to make a complaint at any time to the Data Protection Commission’s Office (DPC), the Irish supervisory authority for data protection issues (https://www.dataprotection.ie/en). We would, however, appreciate the chance to deal with your concerns before you approach the DPC, 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.
3. THE DATA WE COLLECT ABOUT YOU
   1. 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).
   2. We may collect, use, store and transfer different kinds of personal data about you, including:
      • Identity Data (first name, last name, username, marital status, title, date of birth, gender)
      • Contact Data (billing/delivery address, email, phone numbers)
      • Financial Data (bank account, payment card details)
      • Transaction Data (payments to/from you, product/service details)
      • Technical Data (IP address, login data, browser type and version, time zone, operating system, platform, etc.)
      • Profile Data (username, password (for resets), purchases/orders)
      • Usage Data (how you use our website, products, services)
      • Marketing & Communications Data (preferences for receiving marketing/communications)
      • Special Categories of Personal Data (race/ethnicity, health, genetic and biometric data)
   3. If you fail to provide personal data: Where we need to collect data by law, or under a contract with you, and you fail to provide it, we may not be able to perform the contract. We will notify you if this is the case.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
   1. Direct interactions: You may give us data by filling in forms or corresponding with us by post, phone, email or otherwise, e.g. when you apply for products/services, create an account, request marketing, or contact us.
   2. Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns using cookies, server logs and similar technologies.
   3. Third parties or publicly available sources: We may receive personal data about you from analytics providers or other third parties.
5. HOW WE USE YOUR PERSONAL DATA
   1. We will only use your personal data when the law allows us to. Most commonly, we will use your data:
      • To perform a contract with you
      • Where it is necessary for our legitimate interests (or those of a third party) and your interests/fundamental rights do not override those interests
      • Where we need to comply with a legal obligation
   2. Generally, we do not rely on consent as a legal basis for processing your personal data except to send third party direct marketing communications to you via email or text. You have the right to withdraw consent to marketing at any time by contacting us.
6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
   1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
   2. 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 table below.

   Purpose/Activity	Type of Data	Lawful Basis for Processing (including basis of legitimate interest)
   To register you as a new customer	Identity Contact	Performance of a contract with you
   To process and deliver your order including managing payments, fees and charges; collect and recover money owed to us	Identity Contact Financial Transaction Marketing & Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
   To manage our relationship with you, including notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey	Identity Contact Profile Marketing & Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
   To enable you to complete a survey	Identity Contact Profile Usage Marketing & Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
   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	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing & Communications Technical	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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	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 marketing strategy)
   To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing & Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

7. MARKETING
   1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
   2. Promotional Offers from Us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on 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 (marketing).
   3. You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
   4. Third-party Marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
   5. Opting Out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message or by contacting us at any time. Opting out will not apply to personal data provided as a result of a purchase or other transactions.
8. COOKIES
   1. 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, some parts of this website may become inaccessible or not function properly.
   2. Our website uses cookies to distinguish you from other users. This helps us provide a good experience and improve our site.
   3. A cookie is a small file of letters and numbers stored on your browser or hard drive if you agree. Cookies contain information transferred to your hard drive.
   4. We use the following cookies:
      • Strictly necessary cookies: Required for operation of our website (e.g. login, shopping cart, e-billing).
      • Analytical or performance cookies: Recognise/count visitors and see how they use the website to help improve its function.
      • Functionality cookies: Recognise you on return visits, remember preferences, and personalise content.
      • Targeting cookies: Record your visit, pages visited, links followed, and may be shared with third parties for this purpose.
   5. Except for strictly necessary cookies, all cookies will expire after two weeks.
9. CHANGE OF PURPOSE
   1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason compatible with the original purpose. If you want an explanation as to how processing for the new purpose is compatible, please contact us.
   2. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis.
   3. We may process your data without your knowledge or consent, where required or permitted by law.
10. DISCLOSURES OF YOUR PERSONAL DATA
    1. We may share your data with third parties (testing labs, couriers, delivery services, etc.) for the purposes set out in this policy.
    2. We may share your data with third parties in connection with business sales, transfers, or mergers. New owners may use your data in the same way as set out in this policy.
    3. We require all third parties to respect the security of your personal data and treat it in accordance with the law. They may only process your data for specified purposes and in accordance with our instructions.
11. INTERNATIONAL TRANSFERS
    1. When transferring your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
       • Transfer to countries deemed to provide adequate protection by the European Commission
       • Use of contracts approved by the European Commission
       • For US providers, transfer if part of the Privacy Shield (or any EC-approved replacement)
    2. Please contact us if you want further information on the specific mechanism used by us when transferring your data out of the EEA.
12. DATA SECURITY
    1. We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access is limited to those with a business need to know, who are subject to a duty of confidentiality.
    2. We have procedures to deal with any suspected personal data breach and will notify you and any regulator where we are legally required to do so.
13. DATA RETENTION
    1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for legal, regulatory, tax, accounting or reporting requirements. We may keep it longer in the event of a complaint or if litigation is reasonably anticipated.
    2. By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.
    3. In some circumstances, you can ask us to delete your data (see ‘Your Legal Rights’ below).
    4. In some circumstances, we will anonymise your data for research or statistical purposes, in which case we may use it indefinitely without further notice to you.
14. YOUR LEGAL RIGHTS
    1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
       • Request access to your personal data (data subject access request)
       • Request correction of the data we hold about you
       • Request erasure of your data
       • Object to processing where we rely on legitimate interest
       • Request restriction of processing
       • Request the transfer of your data to you or a third party
       • Withdraw consent at any time (where relying on consent)
    2. If you wish to exercise any of the rights above, please contact us.
    3. No fee usually required: You will not have to pay a fee to access your data or exercise other rights. We may charge a reasonable fee if your request is unfounded, repetitive or excessive, or refuse to comply in these circumstances.
    4. What we may need from you: We may need specific information to confirm your identity and ensure your right to access your data (or to exercise other rights). This is a security measure to ensure data is not disclosed to anyone who has no right to receive it. We may also contact you for further information to speed up our response.
    5. Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take longer if your request is complex or you have made a number of requests. We will keep you updated.