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Privacy Policy

1. INTRODUCTION

This is the Privacy Policy of SimplyWell UG (hereinafter: “SimplyWell”, “we”, or “us”). The proper handling of personal data is extremely important to us. We therefore take great care when processing and protecting your personal data. This is done in accordance with the provisions set out in applicable privacy laws (including the General Data Protection Regulation).

To ensure your privacy as far as possible, we adhere to the following core values:

  • Information: We wish to inform you about why and how we use your personal data, as described in this Privacy Policy.

  • Limited collection: We take great care to limit the information we collect and use to only what is necessary for selling our Products and/or providing our Services (as defined below).

  • Security: We take appropriate measures to secure your personal data and require the same from parties that process your data on our behalf. SimplyWell proactively tests its websites and apps on a continuous basis using automated security scans.

  • Individuals’ rights: We respect your rights under applicable privacy laws (including the right to access, correct, or delete your personal data).

This Privacy Policy describes how we implement these core values and how we respect and protect your right to privacy. We strongly urge you to read this statement carefully, as it sets out the basis on which we use your personal data when you:

  • Buy our products online, in-store, or via other SimplyWell points of sale (“Products”);

  • Access our websites, interact with us, or use our services and applications (jointly referred to as “Services”).

WELLVIVA is a brand owned and operated by SimplyWell UG.


2. PERSONAL DATA WE COLLECT AND USE

The personal data we collect about you when you buy our Products or use our Services include the following (jointly referred to as “Personal Data”):

  • Contact details: Name, postal address, telephone number, email address, and delivery address (if applicable).

  • Electronic identification & browsing data: When visiting our websites or apps, we collect data automatically (via cookies and tracking technologies), such as IP address, browsing behavior, and shopping preferences. See our Cookie Policy for details.

  • Account data: For MySimplyWell accounts, we collect name, gender, email, date of birth, and optional preferences (e.g., favorite products, interests).

  • In-store purchases: If you’re a MySimplyWell member, we link purchases to your profile (e.g., purchase history, store location, payment status).

  • Online purchases: Name, email, delivery details, payment method, order history, and optional personalization (e.g., engraved products).

  • Personalized products: Data used for customizations (e.g., names on products, gift card images).

  • Newsletter subscriptions: Email address and preferences for personalized marketing.

  • Recordings (CCTV, calls, events): Video footage in stores, call recordings for service purposes, event photos/videos.

  • Communication data: Emails, social media interactions, complaints, or inquiries.

  • Promotions & contests: Data shared when participating in giveaways, surveys, or sampling campaigns.

  • Reviews & feedback: Product ratings, event feedback, or social media posts.

  • Health data: Only with explicit consent (e.g., allergies for product recommendations).


3. PURPOSES OF USING PERSONAL DATA

We use your Personal Data for:

  • Fulfilling orders & services: Processing purchases, memberships, and customer support.

  • Legitimate business interests: Marketing, customer analysis, fraud prevention, and improving products/services.

  • With your consent: Sending newsletters, personalized ads, or processing health data.

  • Legal compliance: Meeting tax, regulatory, or law enforcement requirements.

You may withdraw consent at any time (see Section 9: Your Rights).


4. SOCIAL MEDIA

When you participate in various social media forums like Facebook, Twitter, Pinterest, Instagram, LinkedIn, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the personal data in your social media profile(s).

SimplyWell is bound by the privacy practices or policies of these third parties, so we encourage you to read the applicable privacy notices, terms of use and related information about how your personal data is used in these social media environments.

Also, depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the pages), certain personal data may be shared with SimplyWell about your online activities and social media profiles (e.g. interests, marital status, gender, user name, photo, comments and content you have posted/shared etc.).


5. SHARING YOUR PERSONAL DATA

We share your Personal Data with the following parties:

Other entities within the SimplyWell UG Group. Your Personal Data will be shared between the responsible SimplyWell UG entities that may use your Personal Data as described in this Privacy Policy.

Third Party suppliers. We engage third parties, from time to time, to help us providing us our Products and Services, including:

- Business partners, suppliers (such as IT service providers) and sub-contractors;

- Contact centres, to assist us on the Consumer Service-department;

- Advertising and media companies that carry out marketing and media activities on our behalf (including affiliate marketing);

- Analytics and search engine providers that assist us in the improvement and optimisation of our website and apps, such as Google Analytics.


In providing their services, these third party suppliers will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require such Third Party suppliers to adequately safeguard your Personal Data and only process it in accordance with our instructions.

Corporate transaction. In addition, Personal Data may be disclosed as part of any merger, sale or transfer of Rituals’ assets.

Third parties in case of legal requirement. We may also disclose your Personal Data if we believe we are required to do so by law.

With consent. We may also disclose information about you, including Personal Data to any other third party, where you have consented or requested that we do so, for example in case of a promotional campaign with another sponsor.


6. INTERNATIONAL DATA TRANSFERS

In most cases your Personal Data will be processed within the European Union. However, please be informed that Rituals may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection to your Personal Data. Rituals or Third Party suppliers we use will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer, more in particular for Personal Data transferred to countries outside the European Economic Area. This means that we entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authority where required..

Data may be transferred outside the EU, with safeguards (e.g., standard contractual clauses). Contact privacy@simplywell.com for details.


7. SECURITY

We will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.

We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Policy. Furthermore, we contractually ensure that any Third Party supplier processing your Personal Data equally provide for confidentiality and integrity of your data in a secure way.


8. DATA RETENTION

We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim.


9. YOUR RIGHTS

Subject to the conditions set forth in the applicable law, you have the following rights with regard to our processing of your Personal Data:


  • Right of access – You have the right to request confirmation if Rituals processes personal data about you, and if such is the case, access to the personal data and additional information. Upon request, we can also provide you with a copy of the personal data undergoing processing;


  • Right to rectification – You have the right to request that Rituals corrects, adjusts or completes your Personal Data if we have inaccurate or incomplete data relating to you. You can also correct, adjust or complete your personal data yourself by updating your profile. We also kindly request you to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to Rituals so that we can ensure that your Personal Data is up-to-date. Rituals will take all reasonable steps to ensure that all Personal Data are correct;


  • Right to withdraw consent – You have the right to revoke your consent for receiving marketing communications at any time, by following the instructions in any marketing communication or by filling in the form as set out below. If we use your Personal Data based on your consent for other reasons than marketing communication, you can revoke your consent by filling the form as set out below;


  • Right to delete - You have the right to request deletion of any irrelevant Personal Data we hold about you when (i) the data is no longer necessary in relation to the purposes for which they are collected; (ii) you withdraw your consent and there is no other legal ground for processing; (iii) you object to the processing in case of direct marketing purposes, or – in any other case – there is no overriding legitimate ground for processing; (iv) we unlawfully processed your data. If you have such a request and all requirements are met, we shall make sure that Rituals erases the data of which we are not under a legal obligation to retain;


  • Right to restriction of data use - You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes, but you require them for the establishment, exercise or defence of legal claims; or (iv) you have objected to data use justified on our legitimate interests pending verification as to whether Rituals has indeed compelling interests to continue the relevant data use;


  • Right to data portability - to the extent that we use your Personal Data for the performance of an agreement with you, and that personal data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to Rituals in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible;
  • Right to object - to the extent that we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. You also have the right to object to profiling activities conducted by Rituals;
  • Right to lodge a complaint - You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Policy or applicable law.

For further information regarding your rights, or to exercise any of your rights, please complete this , and do the following:

  • Select the relevant subcategory; and
  • fill in all the e-mail address(es) that you use and have used for all related Rituals services in the comment box, such as but not limited to registration newsletter, account for the webshop, app for the Wireless Perfume Diffuser etc.

To exercise these rights, contact privacy@wellviva.eu or use our online form.


10. CHANGES TO THIS POLICY

This Privacy Policy may be revised from time to time. If a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.


11. CONTACT US

If you have any queries about this Privacy Policy or our handling of your Personal Data in general, please email us at privacy@wellviva.eu.