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Privacy Policy

Effective Date November 11, 2019

Information We Collect

GPS (“we”, “us”, “our”) may collect personal information directly from you, such as when you register for news and information, contact us online or submit forms through our sites. We may also collect personal information from third parties or automatically through your use of the sites.

For the purpose of this Privacy Notice (“Notice”), “personal information” means any information that identifies or could be used to identify an individual person, including similar terms such as “personal data” or “personally identifiable information” and “sensitive personal information” means any personal information unauthorized disclosure or misuse of which may jeopardize the rights or property of, or is likely to damage the reputation or physical mental health or lead to discriminatory treatment of the individual concerned, or as otherwise defined under applicable law.

Please also be sure to check the end of this Notice for country-specific information that are providing to as required by the relevant applicable law.

Information Collected Directly

We collect information (including sensitive personal information, where applicable) that you provide to us or share on the sites, including:

Registration Information and Requests: Our site and other information available on our site can be accessed without registering. However, you may be required to register in order to use or access some of our services. The information that we collect will vary depending upon the context of your request, but for general inquiries, we require your first and last name and contact information, such as address, telephone number and email address and other relevant information relating to your request. Generally, fields marked with an asterisk are mandatory for processing your inquiry or your registration, other details are optional.

Communications: When you email us, call us or contact us, we maintain records about our interactions and communications with you.

Customer Service and Support: We also maintain records related to customer support and customer service-related requests, including the nature of the request, in order to process questions or comments directed to our customer service team, or to settle complaints. For questions or comments directed to our customer service team relating to an order or invoice, or in the event of a product complaint, we may require additional information about the product, for example, product size, gender, time and place of purchase and additional information about previous inquiries.

Comments and Content: Some areas of the sites may allow you to comment, share or post other content. When you view this content, we keep a record of our content and it may be viewable by other users of the sites. You may ask us to remove such content as set out below.

Marketing and Surveys: If you participate in our direct marketing activities, for example if you fill out a participation or answer card or register for a GPS newsletter, we will process the personal information required for each of these. If you used our online store and a purchase process is not completed, we may send you a reminder email. If you have signed up to participate in a competition or similar advertising campaign, we may use the personal information provided by you to process your participation. For more information, please refer to the conditions of participation for the respective campaign. Where required by applicable law, we will obtain your consent prior to sending you any direct marketing. If you have given consent to receive direct marketing email communications GPS will use the personal information provided by you to further discuss your interest in the company or our products and services; and to send you information that may be of interest regarding the company, its affiliates, and its partners, such as information about special offers, events, e-commerce activities, market research, consumer or customer surveys, competitions and similar advertising campaigns.

Business Relationship Information: We work with external professionals, contractors, suppliers, experts, consultants and others in the operation of our business. For example, when we deliver our services and otherwise make our products and services available, we may engage with suppliers, contractors, consultants and others who provide services or products to us. We also engage with customers and partners related to the provision of our products and services. We may collect information through these third parties. We collect information such as business contact information, accounting and payment related information and other information related to our business relationship with a third party. We may also conduct due diligence and background checks subject to applicable law to ensure the reliability of third parties with whom we conduct business. Automatically Collected Information.

When you visit the sites, some data is automatically transferred from your browser to our server, in order to offer you a better service with personalized information and to make it easier for you to use our sites. We use cookies, pixel tags, web beacons and similar technologies to automatically collect information when users access or use the sites. This data is collected and processed by us or by external service providers on our behalf and includes: information about you collected through your use of our services, including log files, IP address, app and device identifier, advertising ID, location info, browser type and operating system, device type, domain name, the website that led you to our services, the website to which you go after leaving our services, the dates and times you access our services, and the links you click and your other activities within the services. For more information, please refer to the Cookies section below.

Monitoring Communications

With your consent and subject to applicable laws we may monitor and record your calls, emails and other communications with us. We do this for a variety of purposes which include the following: to maintain the security of our communications systems and procedures, for quality control and staff training purposes, fraud detection and prevention, and when we need to see a record of what has been said between us. We will also monitor for regulatory compliance (where applicable) as well as crime prevention and detection purposes.

Use of Personal Information

In the course of conducting our business, we use (with your consent where required by applicable law) personal information (and sensitive personal information, where applicable) to provide and improve our services, to process employment inquiries, to provide information about our products and services, to respond to requests and to otherwise communicate with you and others.

Providing Support and Services: To provide and operate our services and the sites, communicate with you about your use of the sites, respond to your inquiries, provide troubleshooting, fulfill your orders and requests, process your payments, and complaints and inquiries, provide technical support, and for other customer service and support purposes.

Operating our Business: We may use your information to identify usage trends in the use of our sites and analyze the effectiveness of our communications; to detect, prevent, investigate fraud and including (cyber) security monitoring and prevention; to validate your ability to access or use certain products or services; to operate and expand our business activities; where necessary to the administration of our general business, accounting, record keeping and legal functions; and as part of our routine business administration, such as training, compliance auditing and similar internal activities.

Research, Development and Reporting: We may use information to develop, enhance, improve or modify our products and services; to better understand how our products and services impact you and those for whom you care; to track and respond to concerns, including engaging in regulatory monitoring and reporting obligations related to adverse events, product complaints and patient safety, or to conduct data analysis and audits.

Personalization: To tailor content we send or display on the sites in order to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.

Analytics and Improvement: To better understand how users access and use the sites and other products and services, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop additional products, services and features.

Evaluating and Engaging With Third Parties: To identify, evaluate and engage with third parties such as contractors, suppliers and business partners; to conduct due diligence, such as background checks on contractors and suppliers in accordance with applicable law.

General Business Operations: Where necessary for the administration of our general business, accounting, record keeping and legal functions.

Anonymous and De-identified Information: We may de-identify information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry, and for other research and analytics purposes.

Marketing, Surveys and Promotions: For direct marketing and promotional purposes, to send you newsletters, special offers or promotions, and contact you about our products or services, or information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.

Protect Our Rights: To protect the sites and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Notice.

Legally Required: To comply with the law or legal proceedings, such as subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

We will, where required by applicable law, obtain consent from you if we wish to use your personal information for purposes other than those stated in this Notice.

Disclosure of Information

We do not sell your personal information to third parties. In general, we disclose the personal information we collect as follows:

Service Providers: We may share your information with third party service providers, whose services we use for data storage and analytics, for web hosting, data analysis, IT technology, infrastructure and security, including without limitation with third parties whose services we use to provide customer services, for example for communicating with you by email or phone, for market research, carrying out surveys, handling payment transfers, advisory services, maintenance and other similar services. We take steps to confirm that our service providers are capable of providing appropriate security and protection and will agree to adequate privacy and security contractual terms.

Third-Party Advertising and Marketing: Third-party companies that we work with to display online advertising that is more relevant may collect cookie IDs, IP address and other identifiers as well as information about the pages you visit on our sites and other websites, to enable them to display advertising for products and services that may be of interest to you when you visit our website or other websites.

Business Transfers: We may disclose or transfer information, including personal information, as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), including related to due diligence conducted prior to such event where permitted by law.

Legally Required: We may disclose your information if we are required to do so by the law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order) of any jurisdiction.

Protect our Rights: We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of GPS, our customers, or others.

Anonymized and Aggregated Data: We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Cookies, Analytics and Targeted Ads

We and our service providers use cookies, pixels, java script and other tracking mechanisms to track information about your use of our sites and services, and we may combine this information with other information, including personal information, we collect about you. We may also work with third party ad networks, analytics companies, measurement services and others to display advertising on our sites, and to manage our advertising on third party sites, mobile apps and online services.


Cookies are small text files that are stored on your computer or mobile device. Cookies are used in order to make websites work, or work in a better, more efficient way or to allow us to track your activities while using our Site. We use “session cookies” which are deleted as soon as you close your browser, and temporary/permanent cookies, which are stored on your computer or mobile end device for a longer period, until they expire, or are deleted. This helps us to recognize you and remember important information that will make your use of a website more convenient (for example by storing preference settings).

In general, the use of cookies is activated by your browser; however, you can turn off this function. If you do not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies or to delete them.

Clear Gifs, Pixel tags and Other Technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. Unlike cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our sites to, among other things, track the activities of our site users, help us manage content, and compile statistics about usage of our sites. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log Files

Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

Third-Party Analytics

We use third-party services, such as Google Analytics (more information or opt-out) and Adobe Analytics (opt-out) to analyze the usage of our website. We utilize these tools to gather information about users to help enhance the user experience and to improve our sites. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our sites with other information they have collected for their own purposes. Please review these third party's privacy policies, as this Notice does not cover such uses of data by third parties.

Interest-Based Advertising

On some of our sites, we may work with third party ad networks, analytics companies, measurement services and others (collectively “ad companies”) to display advertising on our sites, and to manage our advertising on third party sites, mobile apps and online services. We and these third party ad companies will, and by using our sites you consent that they may use cookies, pixels tags, and other tools to collect activity information on our sites (as well as on third party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third party ad companies use this information to display you more relevant ads and content and to evaluate the success of such ads and its content.

You may also manage your cookie preferences in your browser settings. If you wish to do so, please visit:
Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie Settings in Safari.

Direct Marketing

From time to time, we may send periodic promotional emails to you that we think may be of interest to you, including newsletters, special offers or promotions, in relation to our products or services. We would also like to share your name and email address with other entities within GPS so that we or they may send you information that may be of interest regarding them and their special offers, events, e-commerce activities, market research, consumer or customer surveys, competitions and similar promotional campaigns, but we also cannot do so without your consent. You may opt-out of these communications at any time, and where required by law we will obtain your prior consent to send you such communications.

If you would like to opt-out of receiving further electronic communication from GPS, and/or wish to stop GPS from disclosing your personal information for marketing purposes you may opt-out of such communications by following the opt-out instructions contained in the email, or you can contact us to withdraw your consent. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails with information relating to your account or any services you have requested or received from us.


We have implemented specific organizational, technical, and administrative measures to protect personal information under our control from unauthorized access, use, or disclosure, including, as appropriate, encryption of personal information (and in particular, sensitive personal information), privacy and security impact assessments, and secure access controls among other things. While the security safeguards we have put in place are routinely reviewed and updated, the security of any data transmissions and data storage systems cannot be completely guaranteed.


As a general rule, we will retain your personal information as long as needed to fulfill the purposes outlined in this Notice, and as otherwise necessary to fulfill our legal obligations, resolve disputes, maintain appropriate business records, enforce our agreements or for such longer period as required by applicable law. The retention period depends on the information and the reason for which we have collected it. For example, we generally retain personal data records related to technical support and customer service requests for seven years, unless a longer or shorter retention period is required by law, is necessary in the course of legal obligations, to resolve disputes, maintain appropriate business records, and enforce our agreements proceedings or is otherwise needed for a particular purpose under applicable law.

Third-Party Sites

This Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties. The inclusion of a link on the website does not imply endorsement of the linked site by us or by our affiliates. In some cases, we may permit you to use third-party payment services to make payments. If you wish to make a payment using a payment service, you will be directed to a webpage that is hosted by the payment service and not by us. Any information that you provide through this page will be subject to the applicable payment service’s privacy policy, rather than this Notice. We have no control over, and are not responsible for, any payment service’s use of information collected through any payment service page.

Use of Website by Children

Our sites are not directed towards children and we do not encourage children to participate in providing us with any personal information. We do not knowingly collect any personal information from children under the age of fourteen.

Your Rights

GPS takes reasonable steps to keep your personal information accurate, up to date and complete. You may have a right to request access to, correction of, and deletion under certain circumstances of, your personal information, subject to applicable law. To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. In addition, in some circumstances based on applicable law, you may request that we cease using or sharing personal information about you with our business partners, by contacting us as explained below We will seek to honor those requests consistently with applicable law.

Changes to this Privacy Notice

We may update this Notice from time to time to reflect changes and will post changes by updating the Notice (and effective date) on this page. If we make any material changes that affect how we treat your personal information, we will attempt to notify you in advance, such as by prominently posting a notice on this website or by sending you a notification and seeking your consent to any material changes as required by applicable law. We encourage you to periodically review this website and our Notice to understand how GPS protects your personal information.