PRIVACY POLICY

Welcome to UBR Microbes

The purpose of URB's™ Privacy Policy (“Privacy Policy”) is to inform you of how URB manages, collects, uses, processes and discloses your Personal Data, which is subject to the privacy principles set out in the Privacy Act 1998 (Cth) and the Privacy Act 1993 (CO) and the general law intended to protect your privacy, as amended from time to time. Protecting our customer’s Personal Data and compliance with Applicable Laws is of the utmost importance to URB and a matter we take very seriously.  We are committed to properly managing, protecting and processing your Personal Data in accordance with this Privacy Policy, which applies to all Personal Data we collect through our Platforms or other channels.

When you submit information to us, or sign up as a customer on our website to purchase, view or otherwise browse any of the products, services or content offered by us, you agree and consent to URB (including any Related Corporations and business units) (collectively, the "Companies"), as well as their respective representatives and/or agents collecting, using, disclosing and sharing among themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

Please read and review this Privacy Policy, which will inform you how we collect, use, process and disclose your Personal Data. This Privacy Policy should be read in conjunction with URB's Terms and Conditions, of which this Privacy Policy forms part. This Privacy Policy supplements, but does not supersede nor replace any other consents you may have previously provided to URB in respect of your Personal Data.  We may also collect and process your Personal Data under any exceptions to Applicable Laws, which are not set out in this Privacy Policy. We trust that it will assist you in making an informed decision whether to provide us with any of your Personal Data.

Note this Privacy Policy does not cover information collected from individuals as part of our recruitment and selection process, when we engage contractors or onboard employed by our labour hire agencies. This Privacy Policy also does not apply to the practices of organisations that URB does not own or control, or to people that URB does not employ or oversee even if offers, coupons or links to their websites appear within our Platforms or technology.

1.  INTRODUCTION

1.1 For the purposes of understanding this Privacy Policy, capitalised terms have the following meanings:

1.1a  “Applicable Laws” means the Privacy Act 1998 (Cth), the Privacy Act 1993 (NZ) and their respective subsidiary legislations and regulations, as amended from time to time;

1.1b  "Apps" means our mobile app on iOS and Android and any other app we may own or operate from time to time;

1.1c. “Personal Data” means any data, whether true or not, which is (a) about an individual who can be reasonably identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any Applicable Laws;

1.1d. “Platforms” means collectively URB’s Apps, Social Media and Websites, and any other websites or applications which we may own or operate from time to time;

1.1e. “Related Corporations” means the subsidiary entities of Terrae Voluntas Colombia SAS, a Colombia registered company and Conscious Evolution LLC (DBA Terrae Voluntas), a USA registered company;

1.1f  “Social Media” means URB’s pages and accounts on third-party social media platforms such as Instagram, Facebook, Twitter and Pinterest ’

1.1g  “URB”, “URB Microbes”, “URB Natural Colombia”, "we", "our", "us" means Terrae Voluntas Colombia SAS (COMPANY NUMBER: XX XX XX XX) of (ADDRESS) (COMPANY ID/REGISTRATION) , and includes any subsidiary entities in existence from time to time; and

1.1h  “Website” means the URB website and associated services accessed at the following addresses https://www.urbnaturalcolombia.com or (inclusive of subdomains such as https://*.urbnaturalcolombia.com/) or other internet locations.

2.  WHAT PERSONAL DATA DO WE COLLECT?

2.1 During our relationship with you, we may collect Personal Data from you.  Examples of the types of Personal Data we may collect includes your name, contact details, delivery addresses, email address, birthday, facial image, your shopping or browsing behaviours, voice recording (from customer service calls) and any other personally identifiable information that you have provided us in any form you may have submitted to us, or in the course of any other forms of interaction between you and us.  Where such information pertains to an identified individual - Personal Data may also include network and device data such as IP address and device or advertising identifiers and information we obtain using cookies or other tracking technologies.  We may also collect information about you from third-party sources and platforms (including data validation services, authentication service providers, social networking sites, online marketing and segmentation providers and ad targeting companies) to supplement the information we collect directly from you.

If you provide us with Personal Data relating to a third-party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third-party to provide us with their Personal Data for the respective purposes.

By (1) clicking “Yes” on our Privacy Policy pop-up or any web form referring to this Privacy Policy on any of our online Platforms, (2) submitting your Personal Data to us when signing up for an account on the Website or App, (3) browsing our Website or App, or (4) ordering any of our products and services, you are agreeing to the terms of this Privacy Policy.

3.  HOW DO WE COLLECT YOUR PERSONAL DATA?

3.1 We collect Personal Data from you when:

3.1a You register an account on the Website or the Apps;

3.1b You use any of our related services, such as subscribing to our newsletter or product notifications;

3.1c You browse our products and services or otherwise interact with our Website and Apps;

3.1d You accept our cookies and other tracking technologies on your device;

3.1e You interact with our customer service team or other representatives, for example, via our webform, chat, emails, telephone calls, letters, or face-to-face meetings;

3.1f You interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;

3.1g You sign up to our affiliate marketing partner network;

3.1h You sign up to be a vendor selling to URB, including via URB Marketplace;

3.1i You purchase a gift card for redemption on URB;

3.1j You participate in our promotions and giveaways, initiatives or any request for additional Personal Data such as customer surveys;

3.1k We consult publicly available sources of information, or receive references or referrals from marketing and business partners, Related Companies, and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;

3.1l Your authorised representative submits your Personal Data to us for any purpose reasonably authorised by you, for example if such representative is purchasing our product or service to be delivered to you or as a gift;

3.1m Our third-party analytics and other service providers, business or commercial partners provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or

3.1n You voluntarily submit your Personal Data to us for any reason.

3.2 We do not directly collect your credit card details to process your payment or for customer service purposes.  Your credit card details are collected, processed and stored directly by our third-party payment processors pursuant to their terms of use and privacy policies.  None of your credit card details are permanently stored with us.  However, we may collect your bank account details to process refunds.

4.  HOW WILL YOUR DATA BE USED?

 4.1 We may use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:

4.1a provide, maintain, protect and improve our technology, products and services, and monitor their effectiveness;

4.1b register and maintain your user account and to verify your identity or age;

4.1c process your order for our products or services, process or collect your payment for the order;

4.1d deliver or perform the products or services you purchased, including couriers calling or messaging you to obtain your delivery instructions;

4.1e facilitate you transacting via alternative payment methods (such as Wompi, PayU LATAM, Paypal or Afterpay);

4.1f process your returns or refunds in accordance with our Terms and Conditions;

4.1g provide you with supporting services and functions related to your user account, such as saved items in cart, wish-list, brand or product and browser notifications;

4.1h communicate with you in relation to (i) your queries, requests and feedback, (ii) material changes to our Website and Apps Terms and Conditions, Privacy Policy or other terms and conditions, and (iii) matters relating to the operation of your account via the applicable or appropriate medium including email, SMS, or communicating with you at the telephone number you provide;

4.1i personalise and improve your customer experience when you visit the Website and the Apps, for example by prioritising products and services appearing in your search results or feed, or in communications we send you;

4.1j  monitor and enforce compliance with our Terms and Conditions, including dispute resolution;

4.1k to carry out administration, marketing, planning, account security, fraud detection and loss prevention activities, procurement, product and service development, quality control and research to improve the way we provide products and services to you;

4.1l comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law, regulation or regulator’s directive; and

4.1m ensure our Website and Apps function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimising our Website and Apps.

(collectively, the "Purposes")

4.2 In addition, we may use and disclose your Personal Data for the following purposes, to:

4.2a send you marketing communications in relation to our sales, products, services, promotions or the Platforms;

4.2b send you marketing communications in relation to the sales, products, services or promotions of business partners, including promotional mail together with your order;

4.2c deliver ads that are related to our products and services that are targeted and personalised to your interests, attributes, preferences and experiences on the Platforms or other websites, apps or online platforms;

4.2d enable businesses to deliver ads which are related to their products and services which may be of interest to you;

4.2e provide you with any add-on or premium services;

4.2f invite you to our private customer events;

4.2g process your participation in our promotions and giveaways (including contacting you if you win, displaying your details online, publishing your name in relevant newspapers or disclosing details of winners to relevant authorities, if required by law), initiatives or any request for additional Personal Data such as customer surveys;

4.2h process your participation in our business partners’ loyalty or point redemption programs;

4.2i conduct market and customer research, analysis or tracking;

4.2j promote our products and services on our Platforms;

4.2k manage the administrative and business operations of URB and complying with internal policies and procedures;

4.2l improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls;

4.2m any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page; and

4.2n as part of or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganisation, liquidation, or similar business transaction or corporate event.

(collectively, the  "Additional Purposes" )

4.3 We may also use or disclose your Personal Data for secondary purposes in accordance with Applicable Laws, or with your further consent.

4.4 Finally, we may also collect information about you in an aggregated and anonymous basis - in order to conduct internal analysis of traffic patterns within our Website. This information is used by us to administer and improve our education and training products and services.

5.  WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

5.1 In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to:

5.1a our employees, consultants, temporary workers or other representatives;

5.1b URB Marketplace sellers, who supply and deliver the products or services you ordered through the Website or Apps;

5.1c payment processors, who process your payment on the Website and the Apps;

5.1d logistics providers, such as courier, fulfilment or parcel-pickup services which will deliver your order to you, and parcel return partners;

5.1e business partners who separately maintain an account with you for loyalty or point redemption programs;

5.1f business partners or vendors in connection with the processing of any promotion, event or service organised by us;

5.1g our professional advisers, bankers and auditors;

5.1h agents, contractors or service providers who provide operational services to us or who help provide our services to you, such as online cloud storage and processing, fraud detection and monitoring, marketing optimisation, information technology, telecommunications, market research, customer analysis or tracking, security or other relevant services which requires that entity’s collection, use or disclosure of your Personal Data; and

5.1i any other party whom you authorise us to disclose your Personal Data to.

5.2 We do our best to minimise the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.  However, we may also disclose your Personal Data for secondary purposes if the secondary purpose is related to the Purpose or Additional Purpose and you would reasonably expect us to use or disclose the information for the secondary purpose, otherwise in accordance with Applicable Laws, or with your further consent.

5.3 You acknowledge and agree that, should we sell, merge or otherwise change control of our business, our company or the Website to a third-party:

5.3a we shall be permitted to disclose the Personal Data and other information that we have collected from you to the third-party, without giving notice or seeking prior consent from you; and

5.3b we shall be entitled to assign the benefit of any agreements we have with you to the third-party.

6.  HOW CAN I ACCESS OR CORRECT MY PERSONAL DATA?

6.1 You may access or correct some Personal Data including your name, birthday, shipping and billing addresses by logging in to your user account on the Website or Apps under “Account > My Details” and clicking the “Edit” button under each relevant field.

6.2 For Personal Data that cannot be corrected by you by logging in to your user account on the Website or Apps, you may request to access and correct such Personal Data by submitting a written request to us via our Customer Service contact form.  We may need to request additional information from you to confirm your identity before providing the access or making corrections.

6.3 We will do our best to respond to Personal Data access and correction requests within 30 days.  Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction.  Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws, and we may charge you a reasonable fee for the handling and processing of your Personal Data access request, if permitted by Applicable Laws.

6.4 While URB makes reasonable efforts to provide our users with access to their Personal Data, there may be circumstances in which we are unable to provide such access, including but not limited to: where the information in question is legally privileged, would compromise the privacy or other legitimate rights of other persons, where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the request is clearly excessive or unfounded, or where the information requested comprises proprietary business information.

6.5 While URB makes reasonable efforts to provide our users with access to their Personal Data, there may be circumstances in which we are unable to provide such access, including but not limited to: where the information in question is legally privileged, would compromise the privacy or other legitimate rights of other persons, where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the request is clearly excessive or unfounded, or where the information requested comprises proprietary business information.

7. MARKETING MESSAGES

7.1 If you have said we can, we’ll send you marketing messages by email, SMS, or WhatsApp to keep you aware of what we’re up to and to help you see and find our products.

8. HOW CAN I UNSUBSCRIBE OR DELETE MY ACCOUNT?

8.1 If you wish to withdraw your consent for us to send you marketing communications, you can do this as follows:

8.1a through your account settings on our site under  ‘Your Details ’> ‘Your Communication Preferences’ or in the app via ‘Profile’ > ‘Communication Preferences’;promotional return period, if applicable);

8.1b to withdraw consent for marketing emails - by clicking on the ‘Unsubscribe’ or ‘Update your preferences’ link in the email;

8.1c to withdraw consent for marketing SMS or WhatsApp - by following the steps provided in the SMS or WhatsApp message; or

8.1d by contacting our Customer Service team.

8.2 Once we receive notification that you wish to withdraw your consent for receiving marketing communications, it may take up to five (5) business days for your withdrawal to be reflected in our systems.  Please note you may still receive marketing communications during this period.

8.3 If you withdraw your consent to receive marketing communications through a specific communication mode (e.g. SMS) we may still contact you via other communication modes you have subscribed to (e.g. email).

8.4 Note it is not possible to unsubscribe from non-promotional (transactional) communications relating to your online orders or the operation of your account.

8.5 You may remove your account by logging in to your user account on the Website or Apps under “Account > My Details” and clicking the “Remove Account” button.  We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent.  Once the processing is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for fraud, product recall, compliance, regulatory or other legal purposes.

8.6 Note: If you withdraw your consent for us to use and process your Personal Data for the Purposes or the Additional Purposes or for other purposes, we may no longer be able to provide you with the related products, services or benefits associated with our promotion.

9. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

9.1 You should ensure that all Personal Data you submit to us is complete, accurate, up-to-date and correct.  Failure to do so may result in our inability to provide you with the products and services you have requested.  You should keep us updated of any relevant changes to your Personal Data.  We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of such changes.

9.2 We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organisation is accurate, up-to-date and correct.

9.3 We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured and to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data.  However, we will not be responsible for any unauthorised use of Personal Data by third parties which is attributable to factors beyond our control.  Further, given that no data transmission over the internet can be guaranteed as completely secure, we cannot guarantee 100% the security of any (personal or other) information you transmit to us; and as such we will not be liable for any breach of security or unintended loss or disclosure of information due to our Platforms being linked to the Internet.

10.  DATA RETENTION AND DESTRUCTION

10.1 When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal, compliance or business purposes, we will exercise reasonable measures to ensure such Personal Data is either destroyed or anonymised.  If this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

11. DISCLOSURE OVERSEAS

11.1 URB processes Personal Data in multiple countries.  We may transfer your Personal Data to recipients possibly located outside the country where you live.  If Personal Data is so transferred, we will comply with Applicable Laws in doing so.  This includes: (i) obtaining your consent, unless an exception exists under Applicable Laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.  Recipients of your Personal Data are likely to be located in Colombia, Brazil, United Kingdom, the Philippines, United States of America, Luxembourg, Germany, Japan, Singapore and other countries or jurisdictions depending on the nature of the services those recipients provide to us.

12. COOKIES AND TRACKING TECHNOLOGIES

12.1 URB uses Cookies and Tracking Technologies (such as eTags, pixels, web beacons/ GIFs, local storage, or other identifiers on your device and browser settings) on this Website. Cookies are small text files that we may place on your device to store information in order to recognise you and your device each time you visit our Website or Apps.  We also use cookies and tracking technologies in order to enhance your online experience, including for preference settings, product offer selection, analytics, conversion attribution and fraud reduction. We use both session and persistent tracking cookies. Session cookies are temporary files that are deleted by your browser once you close it, while persistent cookies stay in a browser subfolder until deleted.

12.2 Cookies and tracking technologies used on this website can be divided into four main categories:

12.2a Strictly Necessary - Required for the operation of our website.

12.2b Analytical or Performance - Allow us to recognise and count the number of visitors and to see how visitors move around our Website when using it.

12.2c Functionality - Helps us to recognise you when you return to our Website and allows personalisation.

12.2d Targeting - Records your visit to our Website, including pages and links used and allows targeted advertising.

12.3 URB also uses the services of third-party vendors, who may implement one or more persistent Cookies and Tracking Technologies. The collection, use, and disclosure of information, including Personal Data, collected by third party Cookies and Tracking Technologies are subject to the privacy and data protection policies of the third-party vendors and are not under our control.  These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party Cookies and Tracking Technologies are likely to be analytical or performance cookies or targeting cookies.

12.4 You can find out more information about some of the cookies we use, and the purpose for which we use them in the table here (please note these are non-exhaustive).

How do I manage Cookies and Tracking Technologies?

12.5 You can disable both first party and third party Cookies and Tracking Technologies being stored by activating the setting on your browser that allows you to refuse the setting of all or some Cookies and Tracking Technologies. However, please note that this may result in the loss of Website functionality, restrict your use of the Website or App, or disable some features.

12.6 For more information on Tracking Technologies and Cookies and how to opt-out of them, please visit Your Online Choices.

12.7 We may use third-party service providers to monitor and analyse the use of our Website and Apps.  The primary service providers we use are:

13. GOOGLE ANALYTICS AND GOOGLE OPTIMIZE

13.1 URB uses certain Google Analytics functions.  Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking.

13.2 URB may use Google Analytics features based on Display Advertising, including but not restricted to the following: Google Optimize, Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting.  Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and Google Optimize and customise Google Display Network ads.

13.3 URB also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show URB ads on sites across the internet.  URB and third-party vendors, including Google, use first-party Tracking Technologies (such as the Google Analytics cookie) and third-party Tracking Technologies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on visitors’ past visits to URB, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to URB.

13.4 When you log on to the URB website, URB with the help of Google Analytics may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this policy.

14. FACEBOOK ANALYTICS AND FACEBOOK INSIGHTS

14.1 Facebook Insights is a tool which tracks user interaction on the URB’S Facebook page, allowing page admins to track usage and improve page performance.

14.2 Facebook Analytics is a behavioural analytics solution that helps to track, measure, better understand, and optimise products and customer experience and provides audience information and unifies analytics across devices and channels.

14.3 Facebook’s Privacy Policy can be seen here: https://www.facebook.com/full_data_use_policy.  If you want to opt-out of seeing ads on Facebook based on information we’ve received from other websites and apps, you can control this in your ad preferences: https://facebook.com/ads/preferences.

15. THIRD PARTY SERVICE PROVIDERS / SUBPROCESSORS

14.1 These third-party service providers are processing data for which URB is a Controller, as Processors, on behalf of URB, or they are receiving such data as Controllers, for the specific purpose of performing the services they have been contracted to provide.

16. CONTACTING US

15.1 For any questions relating to your Personal Data or about this Privacy Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Customer Service team via our helpdesk by creating a ticket.

15.2 Emails and letters should clearly state that you are making a data protection query, request or complaint in the subject line to ensure the matter is dealt with expediently.  We will strive to deal with any query, request or complaint promptly and fairly.

15.3 You can find more information about privacy and the protection of your Personal Data on the website of the SIC at https://www.sic.gov.co/.

17. GOVERNING LAW

16.1 This Privacy Policy and your use of this Website shall be governed in all respects by the laws of Colombia.

18. UPDATES ON DATA PROTECTION POLICY

17.1 As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time.  In this regard, URB may update this Privacy Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements at our discretion.

17.2 Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy on our Website, any updates to which will be posted on our Website and viewed at https://www.urbnaturalcolombia.com/privacy-policy .  By continuing to use our Platforms and/or services after the Privacy Policy has been amended, you hereby agree to be bound by the terms of such amended Privacy Policy.  If you do not agree with the terms of this Privacy Policy, as it may be amended from time to time, in whole or part, you must terminate your use of the website. You are encouraged to visit the above Website regularly to ensure that you are well-informed of our latest policies in relation to Personal Data protection.

17.3 Last Updated on 19 December, 2021