Our brand name, the Medna as well as our site the www.medna.co.uk is owned and operated by Medna Consultancy and Management Ltd:

• a private limited company, registered in Malta under company registration number: C 89203
• Registered Address: Mercieca Suite 4, Triq it-Tabib Anton Tabone, Victoria, VCT9020, Gozo, Malta
• Mailing Address: 11 Triq il-Bahhara, Qawra, SPB1545, Malta
• International Mailing address: 20-22 Wenlock Road, London, EC1 4GU, UK

Data Protection Officer: Gabriel Tanti

• Email address: dataprotection@medna.co.uk
• Telephone number: +356 99459382
• Postal Address: Mercieca Suite 4, Triq it-Tabib Anton Tabone, Victoria, VCT9020, Gozo, Malta

We are regulated by the following Data Protection Laws:

• The Maltese Data Protection Act (Chapter 440 of the Laws of Malta) as well as the various subsidiary legislation issued under the same (as may be amended from time to time) – the ‘DPA’;
• The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (as may be amended from time to time)– the ‘GDPR’.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Personal data, or personal information does not include data where the identity has been removed (anonymous data).

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

• Identity Data includes first name, maiden name, last name, username or similar identifier, gender, marital status, title, date of birth, email address.

• Contact Data includes billing address, delivery address, email address and telephone number.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• 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, cookie ID’s, web log information, device identifiers and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services, your browsing activity including intended purchases and aborted baskets, completion of surveys, wish-lists, connection information and statistics on your visits to site and page views, the links you click and other actions you take on our services, within our advertising or e-mail content and participation in promotional activity.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You can update your information at any time by amending your personal information within Your Details section of My Account at www.medna.co.uk or alternatively via our contact us page.

We capture, process and retain personal information from you and any devices you may use when you navigate to a www.medna.co.uk web or mobile view, by transacting, by registering an account and otherwise interacting with us. We may also collect personal information from you if you contact one of our representatives or attend an event.

We may capture customer information, purchase data and browsing behaviour as part of the medna representative loyalty programme. This is so we can optimise and personalise your experience with www.medna.co.uk.

Some more examples of the different methods by which we collect information from and about you include through:

DIRECT INTERACTIONS
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you

• register or purchase our products or services through the site or representatives;
• return a product to our representative;
• apply to join our representative loyalty programme;
• create an account on our website;
• subscribe to our services or publications;
• request marketing to be sent to you;
• contact our customer service team;
• enter a competition, promotion, survey or complete a questionnaire; or
• give us some feedback.

AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. These machine learning algorithms generate content which they apply to personalising your experience and select more specifically the items you have an interest in as well as supporting general service optimisation including bid/ markdown automation. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you and information about the advertisements you have been shown or may have clicked on). Where this information is received by us, we will use this information to further personalise your experience with www.medna.co.uk.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
We may receive personal information about you from various third parties as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google Analytics and Google DoubleClick based outside the EU;

(b) advertising networks such as Amnet based inside the EU and Google Display Network based outside the EU;

(c) Social Network providers such as Facebook based outside the EU;

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU;

Identity and Contact Data from data brokers or aggregators such as Experian based inside the EU;

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Under the GDPR, we must always have a lawful basis for using personal data. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• 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.

• Where we need to comply with a legal or regulatory obligation.

Please see the section “What is the Purpose of Personal Data Collection?” to find out more about the types of lawful basis that we will rely on to process your personal information.

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to 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 accessing your account “My Account”, or by e-mailing or contacting our Customer Services team. For more information about these and other options, please Contact us.

When you apply for representative loyalty account we check and verify your e-mail address. In performing such checks, your information may be disclosed to credit reference agencies such as Experian who keep a record of that information, but these are not credit checks and your credit rating will not be affected. We may contact you by e-mail, phone, text, or SMS in relation to managing your account or the performance of our contract with you including:

• delivery fulfilment, where we need further information from you;
• to give you updates in relation to your account, order or delivery;
• if you haven’t used your account, or your representative membership within a period of 12 months, to give you the opportunity to keep your account or representative status active, at this time we will remind you of the great benefits you may be missing out on. If we fail to hear back from you following three e-mail reminders we will take steps to de-activate your account / representative membership.

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

In general terms, we use the personal information we collect to help www.medna.co.uk better understand you and to enable us to personalise your experience with www.medna.co.uk, including offers, promotions and services to meet your needs.

We use your information to:

• personalise our services, offers and promotions to you and provide you with a personalised experience on our sites;
• operate your online account and your representative loyalty account;
• process your online orders and offline representative purchases;
• offer you site content that includes items that you might like and to keep track of your basket;
• contact you about your account and tell you about important changes to www.medna.co.uk;
• provide, develop and improve our products and services;
• provide you customer service;
• manage promotions, competitions, customer surveys and questionnaires; and
• check and verify your identity, and prevent, mitigate or detect and investigate crime, fraudulent or illegal activities;
• process purchases, payments, customer support and order fulfilment.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below you can request this information by e-mailing your request for this information to dataprotection@medna.co.uk

MARKETING
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You can view and make certain decisions about your personal information use at any time at your account, or by e-mailing or contacting our Customer Services team. All of these options are available by clicking here Contacting us.

In summary:

• amend your options within the “Your Details” section of “My Account” on the Website;
• click on the “unsubscribe” link on the bottom of any of our e-mails to opt of email communications;
• send us an email to dataprotection@medna.co.uk

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 (we call this marketing).

MARKETING COMMUNICATIONS FROM US
In general, you will receive marketing communications from us by email, postal mail, SMS, phone or social media if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

www.medna.co.uk is committed to transitioning over time the basis of its e-mail marketing communications to customer consent. To achieve this we will be gradually transitioning our lawful basis for processing to consent and will do this in a number of ways and over a period of time depending on how you engage with us, and whether you are new to www.medna.co.uk or an existing customer or user of our products or services.

If you have any questions about how we are lawfully processing your information you can request this information by e-mailing your request for this information to dataprotection@medna.co.uk

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal information with any company outside the Medna Holding of companies for marketing purposes.

THIRD-PARTY COOKIES USED FOR RETARGETING
We have relationships with carefully selected third parties who may also set cookies during your visit to be used for remarketing purposes – in other words to show you different products and services based on what you appear to be interested in. This type of advertising is designed to provide you with a selection of products based on what you’re viewing on www.medna.co.uk, which are presented to you by our business partners when you visit other selected websites. The adverts may highlight products you’ve viewed, alternative sizes and colours, as well as products from other categories deemed relevant to your browsing history. The technology behind these adverts is based on cookies.

Disabling these advertisements
We would like to continue to display content that’s relevant to you, however, you can choose to opt out of this type of advertising permanently by deleting our cookies. Please note that if you delete your cookies, we will no longer know that you have opted out, and the banners from Amnet or our other providers from time to time will reappear when you visit other selected websites. You can request more details of our third party service providers from dataprotection@medna.co.uk.

You can use your web browser to:

• delete all cookies;
• block all cookies;
• allow all cookies;
• block third-party cookies;
• clear all cookies when you close the browser;
• open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the internet without storing local data; and
• install add-ons and plug-ins to extend browser functionality.

To find information about controlling cookies see our Cookies Policy.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes at My Account to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or you can make changes by Contacting us at any time.

THE RIGHT TO OBJECT TO PROFILING
Where we process personal information relating to your interaction (transactions, site visits, app usage) with www.medna.co.uk to enable us to personalise your experience with www.medna.co.uk. This processing activity constitutes profiling under the GDPR and we process your personal information in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.

You have the right to object to how your personal information is processed including your right to object to profiling as outlined in this privacy policy. More information on this right to object and how to exercise your rights can be found in section “What Are My Rights?”.

We do see profiling as a beneficial service allowing you to have easier and quicker access to products, services and offers tailored more specifically to your interests, but we respect that not everyone feels the same way and we will be sad to see you go.

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, 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.

CHANGE OF PURPOSE
We will only use your personal information 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.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal information with the parties set out below for the purposes set out in the table in section “How Do We Use Your Personal Data?”.

Internal Third Parties as set out in the section Third Parties.
External Third Parties as set out in the Third Parties.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Please contact dataprotection@medna.co.uk if you wish further information on the third parties we use.

INTERNAL THIRD PARTIES
Other members in the Medna Holding who act as joint controllers or processors within the EEA and who provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES
Service providers acting as processors based in the EEA who provide IT, system administration services, payment providers to facilitate purchases, fulfilment providers to facilitate order management, packaging and delivery and marketing and communications services providers in order to personalise your experience and communicate with you.

• Professional advisers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
• Inland Revenue, HM Revenue & Customs, regulators, law enforcement bodies and other authorities acting as processors or joint controllers based in the EEA who require reporting of processing activities in certain circumstances and otherwise in defence of legal claims.

• Market researchers, fraud prevention agencies and analytics providers.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.

Whenever we transfer your personal information 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:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact dataprotection@medna.co.uk if you wish further information on the specific mechanism used by us when transferring your personal information out of the EEA.

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 information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will not keep your personal data for any longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In addition, this includes that we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies.

When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request to be forgotten at section “What Are My Rights” for further information.

In some circumstances we may anonymise your personal information (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.

Under certain circumstances, you have rights under GDPR, General Data Protection Regulation in relation to your personal information. Please see below to find out more about these rights and access the request form should you wish to make any of these requests:

NO FEE USUALLY REQUIRED
There is not normally any charge for accessing your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

TIME LIMIT TO RESPOND
We will respond to your subject access request within 28 calendar days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

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

YOUR HAVE THE RIGHT TO:

• Request access to your personal information (known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you wish to receive a copy of any information we process about you, please complete the Request Form and send to our team at dataprotection@medna.co.uk.
• Request correction of the personal information 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. You can update your information at any time at your ‘My Account’ or by downloading the Request Form and sending your completed form to customer services. Click here for more information how to Contact us.
• Request to be forgotten via the erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information to comply with local law. Please 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. You can request erasure of your information at any time by downloading the Request Form and sending your completed form to dataprotection@medna.co.uk
• Object to processing of your personal information 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 information 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. You can update your marketing preferences at any time at your ‘My Account’ and/or object to other processing by downloading the Request Form and sending your completed form to customer services. Click here for more information how to Contact us.
• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information 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; or (IV) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. You can request restriction of processing by downloading the Request Form and sending your completed form to customer services. Click here for more information how to Contact us.
• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. You can request the transfer of your personal information by downloading the Request Form and sending your completed form to customer services. Click here for more information how to Contact us.
• Withdraw consent at any time where we are relying on consent to process your personal information. 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. You can withdraw your consent at any time by downloading the Request Form and sending your completed form to customer services. Click here for more information how to Contact us.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

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.

If you wish to exercise any of the rights set out above, please send the completed forms to us to the e-mail or postal address included on the Request Form.

In this Policy the following terms shall have the following meanings: