Privacy Policy

BeMe Wellness – Website Global Privacy Notice

We keep this Privacy Notice under regular review to make sure it is up to date and accurate. This notice was last updated on 15 February 2025. 

Introduction to this Privacy Notice

This Privacy Notice explains how BeMe Wellness, its group and affiliated companies (hereinafter "BeMe") collects, stores, uses, protects and shares your personal information, when you interact with us. For example, when you purchase our products or visit our website.

We will only use your information for reasons you provided in the first place or where we otherwise have a valid basis to do so. 

This notice applies to our global business and your information will be shared internationally (e.g., between the UK, EU, the US and Singapore) for the purposes set out below.

Residents of certain states with comprehensive privacy laws in the US, including California residents, can view our state-specific privacy disclosures by going to Section 6 below.

If you have any questions about the content of this Privacy Notice, the terms used within it, or wish to exercise any of your rights, please contact hello@bemewellness.com.

Categories of data collected and method of collection

Depending on how you use our services, we may collect (and have collected in the prior 12 months) the following categories of personal information:

Your personal information is usually processed when you provide it to us, or our carefully selected service providers (e.g., companies conducting surveys on our behalf), directly. 

Where you use social media sites and interact with our social media pages, we will collect your social media data from those sites, e.g. to understand your preferences and interests. Your personal information can be collected and shared within our group companies. We also collect information indirectly from the tracking technologies used on our site. 

Purposes of processing and corresponding legal bases

Data sharing

In carefully selected scenarios, we share your personal information with third parties. We only do so where we have a lawful reason to do so. 

BeMe has a number of service providers that it has engaged to provide services on its behalf or to you directly:

• Marketing and survey companies that obtain feedback and provide insights on our products and services.

• Cloud storage providers and other hosting services that help us administer, manage and improve this site. 

• BeMe affiliates, business partners and entities within our corporate group to ensure we provide a seamless and efficient service. 

• Government entities, regulatory bodies and law enforcement agencies where valid requests for information are made. 

• Advertising networks.

• Vendors and service providers, including internet service providers; and data analytics providers.

• Operating systems and platforms.

• Social networks.

International transfers

When you access our global site, your personal information will be processed internationally depending on the purpose of processing. This could involve an international transfer outside the country which you reside, including to the United States. Such countries can have data protection laws that are different or less protective than the laws of the country in which you reside. For such transfers, we rely either upon an adequacy decision (which is a country deemed to have an acceptable level of protections to send receive such data from) or upon appropriate safeguards as permitted under applicable law and standards, including relying on Standard Contractual Clauses or other appropriate safeguards permitted under applicable laws (e.g. the General Data Protection Regulation). 

US State Privacy Disclosures

This section provides additional information for residents of certain US states, such as California, and describes our information practices pursuant to applicable state privacy laws such as the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020, and its implementing regulations (the “CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices. 

This section applies to “personal information” or “personal data,” whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt from applicable state privacy laws, nor does it apply to our processing of employee or applicant data. We are committed to maintaining and using de-identified information in compliance with applicable state privacy laws.

Sources of Personal Information. We generally collect personal information from the following categories of sources:

• Directly or indirectly from you; 

• Our affiliates, parent companies, subsidiaries;

• Our business partners;

• Social networks;

• Internet service providers;

• Operating systems and platforms; and

• Our vendors and service providers.

Purposes for Collecting and Disclosing Personal Information. As described in the “Purposes of processing and corresponding legal bases” section above, in general, we collect and otherwise process the personal information we collect for the following business or commercial purposes:

• Taking and facilitating online orders;

• Communicating with customers for marketing purposes;

• Carrying our market research to improve products and services;

• Information shared when engaging with our customer services teams;

• Targeting/advertising activities;

• Complying with legal and regulatory requirements; and/or

• For the purposes of corporate transactions.

Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by applicable state privacy laws. 

Retention of Personal Information. As more fully described in Section 9 Retention below, we retain your personal information for only as long as necessary to operate our service and the purposes for which the information was collected. Where we have committed to maintaining and using personal information in a de-identified form, we agree not to re-identify de-identified data except as permitted by applicable law.

Disclosure of Personal Information to Third Parties and Other Recipients. The categories of personal information we have disclosed for a business purpose (including in the preceding 12 months) include: identifiers, customer records, commercial information, Internet or other electronic network activity information, geolocation data, audio, video, and other electronic data, inferences, and sensitive personal information. The categories of third parties and other recipients to whom we may disclose personal information for a business purpose are listed above in this Privacy Notice.

Sales and Sharing of Personal Information. Applicable state privacy laws define "sale" as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration. The CCPA defines “sharing” to include disclosing or making available personal information to a third-party for purposes of cross-contextual behavioural advertising, and other state privacy laws consider this to be “targeted advertising.”

We do not “sell” or “share” personal information defined above. We also do not sell or share personal information about individuals we know are under age 16.

Your Privacy Rights. Residents of certain US states may be entitled to exercise privacy rights regarding their personal information. These rights may include the following, depending on your state of residence and are subject to certain exceptions:

1. Right to Know/Access. The right to request:

• • The categories or personal information we collected about you;

  • The categories of sources from which the personal information is collected;

  • Our business or commercial purposes for collecting, selling, or sharing personal information;

  • The categories of third parties to whom we have disclosed personal information; and

  • A copy of the specific pieces of personal information we have collected about you.

6. Right to Correct. The right to request that we correct inaccurate personal information.

7. Right to Delete. The right to request we delete your personal information.

8. Right to Opt-Out of Sales and Sharing. Again, we do not “sell” or “share” personal information.

9. Right to Limit Use. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the applicable state privacy laws. 

10. Right to Opt-Out of Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects. We do not use personal information to inform decisions that produce legal or similarly significant effects, so you do not have the right to op-out of this use.

11. Right to Appeal. If we deny your privacy rights request, you may have the right to appeal our decision by sending an email to hello@bemewellness.com and providing information about the decision you are appealing. We will review your appeal and notify you of any decision via email.

12. Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your Privacy Rights. If you are a resident of a state that provides for the above privacy rights and would like to exercise your privacy rights, you may do so via any of the methods described below:

• Email us at hello@bemewellness.com

• Filling out our webform at contact page.

Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your full name and email address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. 

Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at  hello@bemewellness.com, and include in your request a current California address and your attestation that you are a California resident.]

Children

Our online services are not directed to, and we do not knowingly collect personal information from, children under the age of 16. If you are a minor, please do not attempt to send any personal information to us. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us immediately to remove the relevant personal information.

Should we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our systems. 

Contact details

Should you have any questions about the contents of this notice or if you would like to exercise any of your rights, please contact the data protection office at:  hello@bemewellness.com.

Retention

We will retain your personal information for only as long as necessary to operate our service and the purposes for which the information was collected. We might need to also process your information to meet legal, regulatory and accounting obligations, or as otherwise required or permitted by law. We will aim to anonymise and/or aggregate personal information and store such anonymised or aggregated information in order to analyse metrics and trends. 

We retain your information in accordance with our established retention periods. We determine the appropriate retention period for personal information by considering the amount of information processed, its nature and sensitivity, the potential risk of harm and its severity, our business interests, whether we can achieve those purposes through other means, and applicable legal requirements. 

When we no longer require the personal information we have collected about you, we will either delete or otherwise anonymise it.

Security

Keeping your information secure is important to us. We have implemented policies, technical and organisational measures to help protect your information from unauthorised or unlawful processing. 

Even though we take these steps to keep your information secure, you should be aware that the use of the internet is not entirely secure and for this reason we cannot guarantee the security of any information which is transferred from you or to you through the internet. Should you wish to learn more about how to protect your information and your devices against online fraud, please visit www.getsafeonline.org.   

Rights of individuals

Under data protection law, individuals in the EU and UK have rights we need to make you aware of. The rights available to you depend on our reason for processing your information and there are some exemptions to those rights, which means you may not receive all the information you desire. To find out more, contact hello@bemewellness.com on the details provided.

• You have the right to ask us for information pertaining to and copies of your personal information. 

• You have the right to ask us to rectify information you think is inaccurate. 

• You also have the right to ask us to complete information you think is incomplete. 

• You have the right to ask us to erase your personal information in certain circumstances. 

• You have the right to ask us to restrict the processing of your information in certain circumstances. 

• You have the right to object to processing if we are able to process your information because the process is in our legitimate interests. 

• You have the right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. 

• You have the right to complain to your local supervisory authority. For example, in the UK, the supervisory authority is the Information Commissioner's Office (https://www.ico.org.uk/).

• If we process your personal data on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.