Privacy Policy and Cookie Statement
July 2019
Gano Excel (consisting of the Gano Excel family of companies) regards the protection of your privacy and safety of your personal data as extremely important. This privacy policy and cookie statement was last updated on 31 July 2019. Gano Excel reserves the right to make changes to this privacy policy and cookie statement pursuant to the applicable legislation and regulations. You will be informed of any changes and, if necessary pursuant to applicable legislation and regulations, you will be asked for your permission.
Gano Excel is responsible for the Gano Excel website (http://www.ganoexcel.com/) and member registrations, aimed at the distribution and marketing of innovative world-class Ganoderma immunology products. This including the sale of these products in Asia, Australia, North America, South America Asia-Europe and Europe. For the purposes of the EU General Data Protection Regulation (“GDPR”), the data controller is Gano Excel International, located in Malaysia. Our Privacy and Cookie Policy is in accordance with Data Privacy laws, including the GDPR in case we provide our services to individuals in the EU. With this document we would like to inform you about our privacy policy and cookie statement and how we collect, protect, use and share information we collect about you on our website and at our Gano Excel member area and webshop (www.ganoexcel2u.com)
1. What type(s) of data do we collect and for what purposes?
Gano Excel processes data in the following situations:
- When you visit our website and member area; When you browse our website or our member area, we automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system and other preferences that are used to optimize your surfing and shopping experience;
- When subscribing as a new member; when subscribing as a new member, in order to gain access to the member area which allows you to visit your shopping cart, our bonus system, business training modules and more, we collect data that is necessary for us to fulfill our obligations in order to provide you access to the member area. We therefore collect your full name, address, e-mail address, phone number and payment information;
- When you purchase something from our member area webshop; when purchasing something from our member area webshop we collect data that is necessary for us to fulfill our obligations in order to sell and deliver the goods. We therefore collect your full name, address, e-mail address, phone number and payment information;
- When you subscribe as a member we send you e-mails about our products, promotion, corporate announcements and or other updates;
- When asking us questions via e-mail: We collect personal information contained in the email for the purpose of responding to your questions and/or comments;
- For the internal analysis of our services, we use personal data to perform analysis based on sales reports by rank, gender, age, city, country, type of products etcetera. We only use this information for our internal marketing and distribution purposes.
We keep the data we collect to a minimum and only collect your data if we must do so depending on the service we provide.
2. On which legal grounds does Gano Excel collect your data?
Gano Excel only collects data when there is a legal ground to do so. These legal grounds consist of:
- In the performance of an agreement; for example, when you become a distributer by signing up as a member and purchase something in our member area webshop;
- If processing is necessary for compliance with a legal obligation; for instance tax regulations and other laws that require us to keep records and files of sales;
- In case there is a legitimate interest: for example, when the processing enables us to enhance, modify, personalize or otherwise improve our services to the benefit of the members or our website users. Or, to enhance the security of our services and determine if our marketing is effective. Gano Excel is allowed to use your personal data where it is in Gano Excel’s interests to do so, and those interests aren’t outweighed by any potential prejudice to you;
- Based upon your consent: for example, when you subscribe to our newsletters. Every form of data collection we perform based on your consent can be withdrawn.
3. Is your personal data shared?
Gano Excel may share your data with other Gano Excel family companies, and third parties that are support companies working on behalf, and on the instructions, of Gano Excel. With these parties Gano Excel concluded processor agreements if necessary under GDPR regulations with regard to our data processing with regard to EU citizens. Examples of these third party companies are email service providers that process the emails from customers, payment providers that process payments, shipping partners that ship our products to the customers, etc.
Your personal data will only be issued to third parties for the purposes referred to above in this privacy policy and cookie statement and/or exclusively on the basis of the (legal) grounds already mentioned. It is our policy not to share, sell or rent your personal information to any company not directly related to the manufacture, producing or selling of Gano Excel products. Only when (by law) obliged to do so, we will provide your data to authorities, other parties or supervisory bodies.
Be aware that when using a third-party payment provider (for instance a credit card provider), or any other third-party that is (also) the controller of personal data you provide them with, we recommend you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers since these providers operate as a “controller” of the data. In particular, remember that certain providers may be located in or
have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
4. Personal data retention period
Gano Excel keeps your personal data for no longer than is necessary in order to fulfil the purposes referred to in this privacy policy and cookie statement, unless a longer retention period is required by applicable law. For personal data related to purchases through our webshop, in order to comply with legal obligations (such as tax and sales laws and for warranty purposes) we may retain this information as long as we are obliged to do so to comply to said legislation. After terminating your membership, Gano Excel will obtain information which we are not required to store for longer by law, for no longer than is necessary. You can request to have all your information deleted instantly (if and limited to certain data allowed by law).
5. Personal data protection
Gano Excel will store your Personal Data in the country in which Gano Excel is based (i.e. Malaysia). Gano Excel makes sure that your Personal Data is stored and transferred in a way which is secure. Gano Excel will take all reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy and cookie statement. Gano Excel has taken all the necessary technical and organizational measures to protect your personal data. These security measures protect against, among other things, loss, disruption, damage and prevent the unauthorized or unlawful processing or publication of your data. All people employed at Gano Excel have signed a non-disclosure agreement. Furthermore, Gano Excel has limited the number of employees capable of accessing your personal data by limiting the personal that has access to certain region’s servers. If you have any questions about how your personal data is protected, or if there are indications of misuse, please contact us using the details referred at clause 10 below.
6. Your rights as a data subject
You, as a data subject, have the following rights:
- The right to access your data. This means you can submit a request to access the personal data we have collected from you.
- The right to rectification of your data if they are incorrect.
- The right to having your data erased (if allowed so by law).
- The right to object to (future) processing of your data or to limit such processing,
provided there are no legal and statutory grounds for precluding this.
- The right to withdraw certain permission you have given to process.
- The right to data portability/data transferability. This means you can receive the data you issued to Gano Excel in a structured, standard and machine-readable form. You can then transfer this data to another responsible party.
- The right to file a complaint with the local data protection authorities.
To appeal to these rights you can contact the contact details mentioned under article 10 of this privacy policy and cookie statement.
7. Cookies
The website and member area webshop of Gano Excel only uses functional cookies. Cookies are small files which are stored by the web browser when you visit the website and member area webshop of Gano Excel. Gano Excel uses these cookies to make our websites and webshop more user-friendly. Consent is not required for these cookies, as the purpose of these cookies is to improve the performance of the website and webshop. For example, Gano Excel may use these cookies to store your login details and the purchases in your shopping cart. In addition, we use these cookies to ensure that you not always have to provide the same information whenever you visit Gano Excel’s website and webshop.
8. Links to other websites
You should be aware that while you are on our website or in our webshop, you may be directed to other sites that are beyond our control and for which we are not responsible. Because we cannot guarantee that the privacy policies of these websites meet our high standards, we recommend that you read the privacy policy of the website to which you link before you submit any personal information.
9. Age of consent
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
10. Contact information
If you would like to request any of the provisions regarding your data as stated in article 6 of this privacy policy and cookie statement, if you want to register a complaint or simply want more information, please contact our Privacy Compliance Officer at euprivacy@ganoexcel2u.com or by post at:
Gano Excel International Lot 2774, Lebuhraya Bukit Kayu Hitam, Pekan Asun, 06000, Jitra, Kedah Darul Aman, Malaysia.
Tel : + 604 – 917 2888
Fax : + 604 – 917 8197