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Privacy Policy

OXFORD BIOLABS' Code of Conduct on DATA PRIVACY and DATA PROTECTION

Introduction

The Oxford Biolabs Code of Conduct on Data Privacy and Data Protection (the 'Privacy Policy') expresses Oxford Biolabs' commitment to strive to protect the personal data of Oxford Biolabs' Customers, Suppliers and Business Partners. This Privacy Policy applies to all employees of the Oxford Biolabs Group of Companies in their roles as follows:

i) Oxford Biolabs Ltd, Oxford Biolabs Deutschland GmbH and Oxford Biolabs USA LLC as data controllers, and

ii) Oxford Biolabs Ukraine LLC and Keilwert Services LLC as a data processors for the data controllers.

This Privacy Policy indicates how this commitment shall be implemented.

Both Oxford Biolabs Ukraine LLC and Keilwert Services LLC are located in a country, Ukraine, that is categorised by the EU Commission as being a Country with Absence of Adequacy. This Privacy Policy also provides for the safeguards at a similar level of data privacy and data protection to those countries that are regarded as having adequate safeguards.

Article 1 – Scope, Applicability and Implementation Scope

1.1 This Privacy Policy addresses the worldwide processing of personal data of Oxford Biolabs Customers, Suppliers and Business Partners

1.2 This Privacy Policy does not address the processing of personal data of Oxford Biolabs employees.

1.3 This Privacy Policy applies to the processing of personal data by electronic means and in systematically accessible paper-based filing systems.

1.4 Individuals (also known as Data Subjects) keep any rights and remedies they may have under applicable local law. Where this Privacy Policy provides more protection than applicable local law or provide additional safeguards, rights or remedies for individuals, this Privacy Policy shall apply.

1.5 Oxford Biolabs may supplement this Privacy Policy through sub-policies and notices that are consistent with this Privacy Policy.

1.6 This Privacy Policy is binding on Oxford Biolabs. Oxford Biolabs employees must comply with this Privacy Policy and, for all those controlling or processing personal data, shall deposit a signed copy of the Privacy Policy on their employee file, to acknowledge their understanding and commitment to keeping to this Privacy Policy.

1.7 This Privacy Policy enters into force as of May 25th, 2018, and replaces any previous codes of conduct on Data Privacy and Data Protection. They are published on the Oxford Biolabs intranet and all Oxford Biolabs websites.

1.8 Where there is a question as to the applicability of this Privacy Policy, employees shall seek the advice of the Data Protection Officer prior to the relevant processing.

Article 2 – Purposes for processing personal data

Legitimate Business Purposes

2.1 Personal data shall be collected, used, transferred or otherwise processed for one or more of the following legitimate business purposes (“Business Purpose”):

(i) Purposes necessary to conduct Oxford Biolabs business.

This addresses processing necessary for activities such as:

(a) conclusion and execution of agreements with Customers, Suppliers and Business Partners;

(b) to record and financially settle delivered services, products and materials to and from Oxford Biolabs;

(c) marketing, sales, and promotions;

(d) account management;

(e) customer service;

(f) finance and accounting;

(g) research and development;

(h) purchasing;

(i) internal management and control;

(j) external communications;

(k) government and legal affairs;

(l) alliances, ventures, mergers, acquisitions, and divestitures; or

(m) intellectual property and standards management

However, Oxford Biolabs does not store payment card numbers on its servers. Payment card numbers are submitted to payment card authorisation services, which provide Oxford Biolabs with validation information only. Oxford Biolabs does not have access to your personal financial data.

(ii) Business process execution and internal management.

This addresses processing necessary for activities such as managing company assets, conducting internal audits and investigations, and implementing business controls;

(iii) Health, safety and security.

This addresses processing necessary for activities such as those involving health and safety, the protection of Oxford Biolabs and employee assets, and the authentication of Customer, Supplier or Business Partner status and access rights;

(iv) Compliance with legal obligations.

This addresses processing necessary for compliance with a legal obligation to which Oxford Biolabs is subject; or

(v) Vital interests.

This addresses processing necessary to protect a vital interest of an individual.

Consent

2.2 If none of the criteria listed in Article 2.1 applies, or if consent is required by applicable local law, Oxford Biolabs shall obtain explicit consent from the individual before processing their personal data. When seeking consent, Oxford Biolabs shall inform the individual of:

(i) the purposes of the processing for which consent is requested; and

(ii) any other relevant details to seek to ensure fair processing.

Oxford Biolabs shall record each consent provided by individuals and acknowledge the consent through e-mail.

However, if the processing is reasonably necessary to address a direct request of the individual, the individual’s consent shall be implied.

Denial or withdrawal of consent

2.3 The individual may deny or withdraw consent at any time. Processing will be discontinued unless Oxford Biolabs has taken action that relies upon the previously provided consent. In such case Oxford Biolabs will discontinue processing as soon as reasonably practical.

Children

2.4 Oxford Biolabs does not seek to nor knowingly form relationships with minors (individuals under 18 years old). When seeking explicit consent from an individual, this consent shall include acknowledgement that the individual is 18 years old or over. In the event that Oxford Biolabs subsequently learns that an individual in its databases are under 18, any consent provided by that individual will be deemed to have been withdrawn, personal data deleted to the maximum extent allowed under applicable law, and a block placed on that individual from any further trading relationship.

Article 3 – Processing of personal data for supplementary purposes

3.1 Generally, and unless explicit consent has been provided by an individual, personal data shall be initially processed only for the purposes for which it was originally collected. However, personal data may further be processed for a legitimate Business Purpose (Article 2.1 above) of Oxford Biolabs for the following supplementary processes:

(i) transferring the personal data to an archive, under statutory documentation retention requirements;

(ii) conducting internal audits or investigations;

(iii) implementing business controls;

(iv) conducting statistical, historical or scientific research as required for the business operations of Oxford Biolabs;

(v) preparing for or engaging in dispute resolution;

(vi) in pursuit of a legal case requiring the use of relevant personal data;

(vii) managing insurance issues;

(viii) any other legitimate purpose established from time to time by the operation of law, which shall be then updated within this Privacy Policy.

3.2 If an employee is in any doubt whether a process is a supplementary process, they shall consult the Data Protection Officer.

Article 4 – Purposes for processing Sensitive Data

Purposes for processing Sensitive Data

4.1 Oxford Biolabs shall process Sensitive Data only to the extent necessary to serve an applicable Business Purpose. Sensitive Data may be processed under one or more of the following circumstances:

(i) where the individual has explicitly consented to the processing, unless the consent may not be relied upon under applicable local law;

(ii) where processing Sensitive Data is a necessary part of providing services to the individual;

(iii) where Sensitive Data is processed in connection with, and as a necessary part of, the purchase or use by an individual of a Oxford Biolabs product or service;

(iv) where the individual is voluntarily participating in a research project or product test;

(v) as required by or allowed under applicable local law;

(vi) to establish, exercise or defend a legal claim;

(vii) only in respect of racial or ethnic data: for the authentication of Customer, Supplier or Business Partner. Oxford Biolabs may process photos and video images (in some countries photo and video images of individuals qualify as racial or ethnic data);

(vii) to prevent, detect or prosecute (including cooperating with public authorities) suspected fraud, contract breaches, violations of law, or other breaches of the terms of access to Oxford Biolabs sites or assets;

(ix) to protect a vital interest of an individual, but only where it is impossible to obtain the individual’s consent first; or

(x) where necessary to comply with an obligation of international public law (e.g. treaties).

Denial or withdrawal of consent

4.2 The information requirements of Article 2.2 and Article 2.3 also apply to the granting, denial or withdrawal of consent.

Prior Authorisation of Data Protection Officer

4.3 Where Sensitive Data is processed based on a requirement of law other than the local law applicable to the processing, or based on the consent of the individual, the processing requires the prior approval of the Data Protection Officer.

Use of Sensitive Data for supplementary purposes

4.4 Sensitive Data may be processed for supplementary purposes only in accordance with Article 3.

Article 5 – Quantity and Quality of personal data

No excessive data

5.1 Oxford Biolabs shall restrict the processing of personal data to that data which is reasonably adequate for and relevant to the applicable Business Purpose. Oxford Biolabs shall take reasonable steps to securely delete or destroy personal data that is not required for the applicable Business Purpose.

Retention period

5.2 Oxford Biolabs generally shall retain personal data only:

(i) for the period required to serve the applicable Business Purpose;

(ii) to the extent reasonably necessary to comply with an applicable legal requirement; or (iii) as part of documentation required under statutory Documentation Retention requirements

Oxford Biolabs may specify (e.g., in a sub-policy, notice or records retention schedule) a time period for which certain categories of personal data will be kept.

End of retention period

5.3 Promptly after the applicable retention period has ended, the Data Protection Officer shall direct that the personal data be:

(i) securely deleted or destroyed;

(ii) de-identified; or

(iii) transferred to an archive (unless this is prohibited by applicable local law or an applicable records retention schedule).

Quality of personal data

5.4 Personal data should be accurate, complete and kept up-to-date to the extent reasonably necessary for the applicable Business Purpose.

Informing Oxford Biolabs

5.5 Oxford Biolabs will undertake reasonable efforts to ensure that personal data is accurate, complete and up-to-date. However, it is the final responsibility of the individual to inform Oxford Biolabs if their personal data is inaccurate, incomplete or outdated and Oxford Biolabs shall rectify the data in accordance with Article 7.

Article 6 – Informing the individual Information to the individual for each processing

6.1 Oxford Biolabs shall inform the individual concerning:

(i) the Business Purposes for which personal data is processed;

(ii) which member of the Oxford Biolabs Group of Companies is responsible for the processing (as data controller); and

(iii) other relevant information (e.g., the nature and categories of the processed personal data, the categories of Third Parties to which the personal data are disclosed, if any, and how the individual can exercise their rights).

(i) the contact details of the Oxford Biolabs, as data controller, its customer service department and the Data Protection Officer

(ii) the Business Purpose of the processing for which the personal data is intended and the consequences of having incomplete personal data

(iii) the period for which the personal data will be stored or the criteria used to determine that period

(iv) the existence of the individual’s rights (see Article 7 below)

(v) the right to lodge a complaint (see Article 17 below)

(viii) the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

(ix) the existence of this Privacy Policy, published on Oxford Biolabs websites, as providing adequate safeguards for the transfer of data to a member of the Oxford Biolabs Group of Companies that is located in a Country with Absence of Adequacy.

(x) a statement that personal data will not be transferred, sold, leased or rented to a Third Party data controller, except as required under applicable law.

Personal data not obtained from the individual

6.2 To the extent required by applicable law, where personal data has not been obtained directly from the individual, Oxford Biolabs shall provide the individual with information as required by Article 6.1, as well as:

(i) which Oxford Biolabs company was in receipt of this data;

(ii) the source of that personal data, including if publicly accessible;

(iii) the categories of personal data concerned;

This communication shall occur no later than the time the personal data is recorded in a Oxford Biolabs database.

Exceptions

6.3 The requirements of Article 6.2 may be set aside if:

(i) it is impossible or would involve a disproportionate effort to inform the individual; or (ii) such provision of information would result in disproportionate cost.

Article 7 – Rights of individuals

Rights of individuals

7.1 Individuals have the right to request an overview (Right of Access) of their personal data processed by or on behalf of Oxford Biolabs. Where reasonably possible, the overview shall contain information regarding the source (if reasonably available), type, purpose and categories of recipients of the relevant personal data. If the personal data is incorrect, incomplete or not processed in compliance with applicable law or this Privacy Policy, the individual has the right, as appropriate, to have their personal data rectified (Right of Rectification), deleted (Right of Erasure) or blocked (Right to withdraw consent). The individual has the right to object to the processing of her personal data on the basis of compelling grounds related to her particular situation (Right of Restriction of Processing). The Individual also has the right for their personal data to be received by them or transferred to a Third Party using a commonly-used electronic format (Right of Data Portability).

Procedure

7.2 To access, rectify, delete, or block personal data or to object to the processing, the individual should send their request or objection to the contact person or contact point indicated in the relevant communication. If no contact person or contact point is indicated, the individual may send their request or objection to Oxford Biolabs through the contact section of the relevant Oxford Biolabs website, or they may contact the Data Protection Officer. Prior to fulfilling the request of the individual, Oxford Biolabs may require the individual to:

(i) specify the type of personal data in question;

(ii) specify, to the extent reasonably possible, the data system in which the personal data likely is stored;

(iii) specify the circumstances in which Oxford Biolabs obtained the personal data;

(iv) show proof of their identity; and

(v) in the case of rectification, deletion, or blockage, specify the reasons why the personal data is incorrect, incomplete or not processed in accordance with applicable law or the Privacy Policy.

Response period

7.3 Without undue delay, and in any case within four weeks of Oxford Biolabs receiving the request or the objection, the Data Protection Officer shall inform the individual in writing either:

(i) of Oxford Biolabs position with regard to the request or the objection and any action Oxford Biolabs has taken or will take in response, or

(ii) the ultimate date on which they will be informed of Oxford Biolabs position, which date shall be no later than eight weeks thereafter.

Complaint

7.4 An individual may file a complaint in accordance with Article 17 if:

(i) the response to the request or the objection is unsatisfactory to the individual (e.g., the request is denied); or

(ii) the individual has not received a response as required by Article 7.3.

Denial of requests

7.5 Oxford Biolabs may deny an individual’s request or objection if:

(i) the request or objection does not meet the requirements of Articles 7.1 and 7.2;

(ii) the request or objection is not sufficiently specific;

(iii) the identity of the relevant individual cannot be established by reasonable means; or (iv) the request or objection is made within an unreasonable time interval of a prior request or objection or otherwise; or constitutes an abuse of rights, for instance because of its repetitive character. A time interval between requests of six months or less shall generally be deemed to be an unreasonable time interval. Before denying a request or objection, employees shall seek the advice of the Data Protection Officer.

Article 8 – Security Requirements

Data security

8.1 Oxford Biolabs shall take appropriate commercially reasonable technical, physical and organisational measures to protect personal data from misuse or accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access.

Employee access

8.2 Employees shall be provided access to personal data only to the extent necessary to serve the applicable Business Purpose and to perform their job.

Confidentiality obligations

8.3 Employees who access personal data shall meet their confidentiality obligations as specified by their contract of employment, and other Oxford Biolabs policies and procedures.

Article 9 – Direct Marketing

Explicit consent for direct marketing

9.1 To the extent required by applicable law, when processing personal data for the purpose of making direct marketing communications, Oxford Biolabs will obtain their explicit consent of the targeted individual. In every subsequent direct marketing communication that is made to the individual, the individual shall be offered the opportunity to withdraw their consent (opt-out) of further marketing communication.

Objection to marketing

9.2 If the individual objects to receiving marketing communications from Oxford Biolabs, or withdraws their consent to receive such materials, Oxford Biolabs will take steps to refrain from sending further marketing materials, and any other material not connected with a Business Purpose, as specifically requested by the individual. Oxford Biolabs will do so within the time period required by applicable law.

Article 10 – Automated Decision Making

Automated decisions

10.1 Automated tools may be used to make decisions about individuals but decisions may not be based solely on the results provided by the automated tool. This restriction does not apply if:

(i) explicit consent has been provided by the individual to the contrary;

(i) the use of automated tools is required or authorised by law; or

(ii) the decision is made by Oxford Biolabs for purposes of entering into or performing a contract provided that:

(a) the underlying request leading to a decision by Oxford Biolabs was made by the individual (e.g., where automated tools are used to qualify contest entries or process requests from Customers); or

(b) suitable measures are taken to safeguard the legitimate interests of the individual (e.g., the individual has been provided with an opportunity to express their point of view).

Article 11 – Transfer of personal data to Third Parties

Transfer to Third Parties

11.1 This Article sets forth requirements concerning the transfer of personal data from Oxford Biolabs to a Third Party. Note that a transfer of personal data includes situations in which:

(i) Oxford Biolabs discloses personal data to Third Parties (e.g., in the context of corporate due diligence); or

(ii) Oxford Biolabs provides remote access to personal data to a Third Party.

Third Party Data Controllers and Third Party Data Processors

11.2 There are two categories of Third Parties:

(i) Third Party Data Processors: these are Third Parties that process personal data solely on behalf of Oxford Biolabs and at its direction (e.g., providers that host accounting software, order management software, customer relationship management software, payment software); and

(ii) Third Party Data Controllers: these are Third Parties that process personal data and determine the purposes and means of the processing.

Transfer for applicable Business Purposes only

11.3 Oxford Biolabs shall transfer personal data to a Third Party only as necessary to serve the Business Purpose for which the personal data is processed (including supplementary purposes as per Article 3 or purposes for which the individual has provided consent in accordance with Article 2).

Third Party Data Controllers

11.4 Oxford Biolabs shall not transfer, sell, lease, or rent personal data to a Third Party data controller except as required under applicable law.

Third Party Data Processors

11.5 Third Party data processors may process personal data only if the third party data processor has a written contract with Oxford Biolabs. The contract shall include provisions addressing the following:

(i) the Third Party data processor shall process personal data only in accordance with Oxford Biolabs instructions and for the purposes authorised by Oxford Biolabs;

(ii) the Third Party data processor shall keep the personal data confidential;

(iii) the Third Party data processor shall take appropriate technical, physical and organizational security measures to protect the personal data; and

(iv) the Third Party data processor shall not permit subcontractors to Process personal data in connection with its obligations to Oxford Biolabs without the prior written consent of Oxford Biolabs. Furthermore, contracts with Third Party data processors shall include, as appropriate, provisions addressing the following:

(v) Oxford Biolabs has the right to review the security measures taken by the Third Party data processor and the third party data processor shall submit its relevant data processing facilities to audits and inspections by Oxford Biolabs or any relevant government authority; and

(vi) the Third Party data processor shall promptly inform Oxford Biolabs of any Data Breach involving personal data, without undue delay.

All such contracts shall be drafted in consultation with the Data Protection Officer.

Transfer of personal data to a Country with Absence of Adequacy

11.6 This Article sets forth additional rules for the transfer of personal data to a Third Party located in a country that is not considered by the EU Commission to provide an ‘adequate level of protection’ for personal data (Country with Absence of Adequacy). Personal data may be transferred to a Third Party located in a Country with Absence of Adequacy only if:

(i) a contract has been concluded between Oxford Biolabs and the relevant Third Party that provides for safeguards at a similar level of protection as that provided by this Privacy Policy; the contract shall conform to any model contract required under applicable local law (if any);

(ii) the Third Party has implemented binding corporate rules or a similar transfer control mechanism which provide adequate safeguards as required under applicable law;

(iii) the transfer is necessary for the performance of a contract with the Customer, Supplier or Business Partner or to take necessary steps at the request of the Customer, Supplier or Business Partner prior to entering into a contract;

(iv) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Oxford Biolabs and a Third Party (e.g. in case of recalls);

(v) the transfer is necessary to protect a vital interest of the individual;

(vi) the transfer is necessary for the establishment, exercise or defense of a legal claim;

(vii) the transfer is required by any applicable law to which the relevant Oxford Biolabs Group Company is subject; or

(viii) the individual has consented to such transfer.

To the extent permitted by law, items (vii) and (viii) above require the prior approval of the Data Protection Officer.

Consent for transfer

11.7 When seeking consent pursuant to Article 11.6 (viii), the individual shall be first provided with the following information:

(i) the purpose of the transfer;

(ii) the identity of the transferring member of the Oxford Biolabs Group of Companies;

(iii) the identity or categories of Third Parties to which the personal data will be transferred;

(iv) the categories of personal data that will be transferred;

(v) the country to which the personal data will be transferred; and

(vi) the fact that the personal data will be transferred to a Country with Absence of Adequacy.

Transfers between NonAdequate Countries

11.8 This Article sets forth rules for transfers of personal data that was collected in connection with the activities of a member of the Oxford Biolabs Group of Companies located in a Country with Absence of Adequacy to a Third Party also located in a Country with Absence of Adequacy. In addition to the grounds listed in Article 11.6, these transfers are permitted if they are:

(i) necessary for compliance with a legal obligation to which the relevant member of the Oxford Biolabs Group of Companies is subject;

(ii) necessary to serve the public interest; or

(iii) necessary to satisfy a Business Purpose of Oxford Biolabs.

Article 12 – Overriding Interests

Overriding Interests

12.1 Some of the obligations of Oxford Biolabs or rights of individuals under this Privacy Policy may be overridden if, under the specific circumstances at issue, a pressing legitimate need exists that outweighs the interest of the individual (Overriding Interest). An Overriding Interest exists if there is a need to:

(i) protect the legitimate business interests of Oxford Biolabs including:

(a) the health, security or safety of individuals;

(b) Oxford Biolabs intellectual property rights, trade secrets or reputation;

(c) the continuity of Oxford Biolabs business operations;

(d) the preservation of confidentiality in a proposed sale, merger or acquisition of a business; or

(e) the involvement of trusted advisors or consultants for business, legal, tax, or insurance purposes.

(ii) prevent or investigate suspected or actual violations of:

(a) law (including cooperating with law enforcement);

(b) contracts; or

(c) or Oxford Biolabs policies; or

(iii) otherwise protect or defend the rights or freedoms of Oxford Biolabs, its employees or other persons.

Exceptions in the event of Overriding Interests

12.2 If an Overriding Interest exists, one or more of the following obligations of Oxford Biolabs or rights of the individual may be set aside:

(i) Article 3.1 (Use of personal data for a supplementary purpose);

(ii) Article 6.1 (Information to the individual);

(iii) Article 7.1 (Rights of individuals);

(iv) Article 8 (Data Security); and

(v) Articles 11.4, 11.5 and 11.6 (i) (Third Party data controller contracts, Third Party data processor contracts, Transfer of personal data to a Country with Absence of Adequacy).

Sensitive Data

12.3 The requirements of Article 4.1 (Sensitive Data) may be set aside only for the Overriding Interests listed in this Article 12.1(i)(a), (c) and (e), (ii) and (iii).

Consultation with the Data Protection Officer

12.4 Setting aside obligations of Oxford Biolabs or rights of individuals based on an Overriding Interest requires the prior consultation of the Data Protection Officer.

Information to the individual

12.5 Upon request of the individual, Oxford Biolabs shall inform the individual of the Overriding Interest that led to the setting aside of Oxford Biolabs obligations or the rights of the individual, unless the particular Overriding Interest sets aside the requirements of Articles 6.2 or 7.2, in which case the request shall be denied.

Article 13 – Supervision and compliance

Data Protection Officer

13.1 Oxford Biolabs shall appoint a Data Protection Officer who is responsible for:

(i) supervising compliance with this Privacy Policy;

(ii) providing weekly updates to the Managing Director of Oxford Biolabs Ltd and quarterly reports to the Board of Directors of Oxford Biolabs Ltd on data protection risks and compliance issues; and

(iii) coordinating official investigations or inquiries into the processing of personal data by a public authority.

(iv) the development of the policies, procedures and system information (as required by Article 14);

(vi) planning training and awareness programmes (Article 15);

(vii) monitoring and reporting on compliance with this Privacy Policy;

(viii) collecting, investigating and resolving privacy inquiries, concerns and complaints; and

(ix) determining and updating appropriate sanctions for violations of This Privacy Policy (e.g., disciplinary standards).

(x) informing the individual in writing (as required by Article 7.4);

(xi) directing that personal data is securely deleted or destroyed, de-identified or transferred to an Archive promptly after the end of the retention period (as required by Article 5.3);

(xii) determining how to comply with the Privacy Policy when there is a conflict with applicable law (as required by Article 20.2);

(xiii) undertaking Data Protection Impact Assessments; and

(ix) informing the Board of Directors of any new legal requirement that may interfere with Oxford Biolabs ability to comply with this Privacy Policy (as required by Article 20.3).

The contact details of the Data Protection Officer shall be published on each Oxford Biolabs internet website.

Default Data Protection Officer

13.5 If no Data Protection Officer has been designated, the Managing Director of Oxford Biolabs is responsible for supervising compliance with the Privacy Policy.

Article 14 – Policies and procedures

Policies and procedures

14.1 Oxford Biolabs shall develop and implement policies and procedures to comply with this Privacy Policy.

System information

14.2 Oxford Biolabs shall maintain readily available information regarding the structure and functioning of all systems and processes that process personal data (e.g. inventory of systems and processes, privacy impact assessments).

Article 15 – Training

Employee training

15.1 Oxford Biolabs shall provide training on this Privacy Policy and other privacy and data security obligations to employees who have access to or responsibilities associated with managing personal data.

Article 16 – Monitoring compliance

Audits

16.1 Oxford Biolabs shall periodically arrange an audit of business processes and procedures that involve the processing of personal data for compliance with this Privacy Policy at the request of the Data Protection Officer.

Applicable professional standards of independence, integrity and confidentiality shall be observed when conducting an audit. The results of any audit shall in all cases be presented to the Board of Directors at the following Board Meeting.

Annual Report

16.2 The Data Protection Officer shall produce an annual Customer, Supplier and Business Partner privacy report for consideration at the Board Meeting immediately following the 31st January each year.

Article 17 – Complaint procedure

Complaint to Data Protection Officer

17.1 Individuals may file a complaint regarding compliance with this Privacy Policy with the Data Protection Officer, who shall initiate an investigation and:

(a) when necessary, advise the organization on the appropriate measures for compliance; and

(b) when measures are undertaken, monitor the steps designed to achieve compliance until all compliance measures are completed.

The Data Protection Officer may consult with any government authority having jurisdiction over a particular matter about the measures to be taken.

Reply to the individual

17.2 Within four weeks of Oxford Biolabs receiving a complaint, the Data Protection Officer shall inform the individual in writing either:

(i) of Oxford Biolabs position with regard to the complaint and any action Oxford Biolabs has taken or will take in response; or

(ii) the ultimate date on which she will be informed of Oxford Biolabs position, which date shall be no later than twelve weeks thereafter.

Complaint to the Managing Director of Oxford Biolabs Ltd

17.3 An individual may file a complaint with the Managing Director of Oxford Biolabs if:

(i) the resolution of the complaint by the Data Protection Officer is unsatisfactory to the individual (e.g., the complaint is rejected);

(ii) the individual has not received a response as required by Article 17.2; or

(iii) the time period provided to the individual pursuant to Article 17.2 is, in light of the relevant circumstances, unreasonably long and the individual has objected but has not been provided with a shorter, more reasonable time period in which they will receive a response.

Statutory rights

17.4 The operation of the Complaints procedure outlined in this Article shall not effect the statutory rights of the individual, including the right of complaint to the relevant supervisory authority.

Article 18 – Legal issues

Local law and jurisdiction

18.1 Any processing by Oxford Biolabs of personal data shall remain to be governed by applicable local law. Individuals keep any rights and remedies they may have under applicable local law. Local public authorities having jurisdiction over the relevant matters maintain their authority.

Specific provision when Data Protection Authorities in EEA have jurisdiction under local law

18.2 If a Data Protection Authority of one of the EEA countries has jurisdiction under its applicable data protection law to evaluate data transfers by an Oxford Biolabs company established in its country, such Data Protection Authority may evaluate these data transfers also against this Privacy Policy.

Protection provided by the Privacy Policy

18.3 Where this Privacy Policy provides more protection than applicable local law or provide additional safeguards, rights or remedies for individuals, this Privacy Policy shall apply.

Supervisory Authority for enforcement of this Privacy Policy

18.4 Except in the case of jurisdiction of a Data Protection Authority of one of the EEA countries pursuant to Article 18.2, compliance with this Privacy Policy shall be exclusively supervised by the Information Commissioners Office in the United Kindgom.

Available remedies and burden of proof

18.7 Under this Privacy Policy, individuals shall only be entitled to remedies available to individuals under the United Kingdom Data Protection legislation. Regarding the burden of proof in respect of damages, it will be for the individual to demonstrate that they have suffered damage and to establish facts which show it is plausible that the damage has occurred because of a violation of this Privacy Policy.

Article 19 – Sanctions for non-compliance

Non-compliance

19.1 Non-compliance of Oxford Biolabs employees with this Privacy Policy may result in disciplinary action up to and including termination of employment.

Article 20– Changes to the Privacy Policy

20.1 Any changes to this Privacy Policy require the prior approval of the Managing Director of Oxford Biolabs Ltd.

20.2 Any amendment shall enter into force after it has been approved and published on the Oxford Biolabs intranet.

20.3 Any request, complaint or claim of an individual involving this Privacy Policy shall be judged against the version of this Privacy Policy that is in force at the time the request, complaint or claim is made.

ANNEX 1 Definitions

ARCHIVE shall mean a collection of personal data that is no longer necessary to achieve the purposes for which the personal data originally were collected or that are no longer used for general business activities, but are used only for historical, scientific or statistical purposes, dispute resolution, investigations or general archiving purposes. An archive includes any data set that is subject to appropriately enhanced security and has restricted access.

BUSINESS CONTACT INFORMATION shall mean personal information typically found on a business card that is used by an individual in the conduct of her employment.

BUSINESS PARTNER shall mean any (a) individual or (b) individual associated with an entity, other than a Customer or Supplier, which has a business relationship or strategic alliance with Oxford Biolabs (such as a joint marketing partner, joint venture or joint development partner).

BUSINESS PURPOSE shall mean a purpose for processing personal data as specified in Article 2 or 3 or for processing Sensitive Data as specified in Article 4. .

COUNTRY shall mean each country in which a group company is established.

COUNTRY WITH ABSENCE OF ADEQUACY shall mean a country that is deemed not to provide an “adequate” level of data protection, under the determination of the EU Commission.

CUSTOMER shall mean any (a) individual or (b) individual associated with an entity, which purchases or may purchase a Oxford Biolabs product or service.

DATA BREACH shall mean any actual or suspected theft, or unauthorized processing, loss, use, disclosure, or acquisition of, or access to, any data.

DATA CONTROLLER shall mean the entity or natural person which alone or jointly with others determines the purposes and means of the processing of personal data.

DATA PROCESSOR shall mean the entity or natural person which Processes personal data on behalf of the Data Controller.

EEA (or European Economic Area) shall mean all Member States of the European Union, plus Norway, Iceland and Liechtenstein.

EMPLOYEE shall mean an employee, job applicant or former employee of Oxford Biolabs.

GENERAL DATA PROTECTION REGULATION shall mean the Regulation 2016/679 of the European Commission on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

OVERRIDING INTEREST shall mean a pressing legitimate need that under specific circumstances outweighs the interest of the individual. personal data personal data shall mean any information relating to an identified or identifiable individual where the individual is associated with a Oxford Biolabs Customer, Supplier or Business Partner.

OXFORD BIOLABS shall mean the Oxford Biolabs Group of Companies.

OXFORD BIOLABS GROUP OF COMPANIES shall mean Oxford Biolabs Ltd, Oxford Biolabs Deutschland GmbH, Oxford Biolabs USA LLC, Oxford Biolabs Ukraine LLC, Keilwert Services LLC, and any company or legal entity of which one of these companies, directly or indirectly owns more than 50% of the issued share capital, has 50% or more of the voting power at general meetings of shareholders, has the power to appoint a majority of the directors, or otherwise directs the activities of such other legal entity;

SENSITIVE DATA shall mean personal data that reveals an individual’s racial or ethnic origin, political opinions, or membership in political parties or similar organisations, religious or philosophical beliefs, membership in a professional or trade organisation or union, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning physical or mental health or mental health including any opinion thereof, addictions, criminal offences, criminal records, proceedings with regard to criminal or unlawful behaviour, social security numbers issued by the government or similar identifying references, or data concerning a natural person’s sex life or sexual orientation.

SUPPLIER shall mean any (a) individual or (b) individual associated with an entity, which provides goods or services to Oxford Biolabs (such as an agent, consultant or vendor).

THIRD PARTY shall mean any person or entity (e.g., an organisations or government authority) that is not a member of the Oxford Biolabs Group of Companies.

General

Terms & Conditions

Updated on: 16th February 2017

Oxford Biolabs Ltd. (hereafter referred to as Oxford Biolabs) operates its websites and welcomes their use by customers and others. The sites, blog, forum, and related services are designed to educate and inform, and we encourage you to express yourself freely. However, it is important to be responsible and respectful in what you write. Being critical is fine, but rudeness and personal attacks are not. In particular, make sure that none of the prohibited items listed below appear in your content or what you link your content to (for example spam, viruses, or hate content).

Terms of Service

The following terms and conditions govern all use of the http://www.trx2.com, http://melaniq.com, and http://oxfordbiolabs.com websites, as well as all other websites operated from time to time by Oxford Biolabs (hereinafter referred to together as the ‘Website’) and all content, services and products available at or through the Website, including, but not limited to associated blogs, forums, and websites. The Website is owned and operated by Oxford Biolabs. The Website is offered for use subject to your acceptance without modification of all of the terms and conditions contained herein and all other operating rules, policies (including, without limitation, Oxbiolabs Content Privacy Policy) and procedures that may be published from time to time on the Website by Oxford Biolabs (collectively, the “Agreement”).
 
Please read this Agreement carefully before using the Website. By using any part of the Website, you agree to become bound by the terms and conditions of this Agreement. If you do not agree to all the terms and conditions of this agreement, then you may not use any of the services contained within the Website. If these terms and conditions are considered an offer by Oxford Biolabs Ltd, acceptance is expressly limited to these terms. Usage of the Website is available only to individuals who are at least 13 years old.

Responsibility of Contributors

If you operate a blog, comment on a blog, post material to the Website, post links on the Website, or otherwise make (or allow any third party to make) material available by means of the Website (any such material, “Content”), you are entirely responsible for the content of, and any harm resulting from, that Content. That is the case regardless of whether the Content in question constitutes text, graphics, an audio file, or computer software. By making Content available, you represent and warrant that:
  • - the downloading, copying and use of the Content will not infringe the proprietary rights, including but not limited to the copyright, patent, trademark or trade secret rights, of any third party;
  • - if your employer has rights to intellectual property you create, you have either (i) received permission from your employer to post or make available the Content, including but not limited to any software, or (ii) secured from your employer a waiver as to all rights in or to the Content;
  • - you have fully complied with any third-party licenses relating to the Content, and have done all things necessary to successfully pass through to end users any required terms;
  • - the Content does not contain or install any viruses, worms, malware, Trojan horses or other harmful or destructive content;
  • - the Content is not spam, is not machine- or randomly-generated, and does not contain unethical or unwanted commercial content designed to drive traffic to third party sites or boost the search engine rankings of   third party sites, or to further unlawful acts (such as phishing) or mislead recipients as to the source of the material (such as spoofing);
  • - the Content is not libellous or defamatory (more info on what that means), does not contain threats or incite violence towards individuals or entities, and does not violate the privacy or publicity rights of any third party;
  • - your Content is not getting advertised via unwanted electronic messages such as spam links on newsgroups, e-mail lists, other blogs and web sites, and similar unsolicited promotional methods;
  • - your Content is not named in a manner that misleads your readers into thinking that you are another person or company. For example, your blog or comment’s URL or name is not the name of a person other than yourself or company other than your own;
  • - you have, in the case of Content that includes computer code, accurately categorized and/or described the type, nature, uses and effects of the materials, whether requested to do so by Oxford Biolabs or otherwise.
Without limiting any of those representations or warranties, Oxford Biolabs has the right (though not the obligation), in Oxford Biolabs’ sole discretion, to (i) refuse or remove any content that, in Oxford Biolabs’ reasonable opinion, violates any Oxbiolabs Content Privacy Policy or is in any way harmful or objectionable, or to (ii) terminate or deny access to and use of the Website to any individual or entity for any reason.

Responsibility of Website Visitors

Oxford Biolabs has not reviewed, and cannot review, all of the material, including computer software, posted to the Website, and cannot therefore be responsible for that material’s content, use or effects. By operating the Website, Oxford Biolabs does not represent or imply that it endorses the material there posted, or that it believes such material to be accurate, useful or non-harmful. You are responsible for taking precautions as necessary to protect yourself and your computer systems from viruses, worms, Trojan horses, and other harmful or destructive content. The Website may contain content that is offensive, indecent, or otherwise objectionable, as well as content containing technical inaccuracies, typographical mistakes, and other errors. The Website may also contain material that violates the privacy or publicity rights, or infringes the intellectual property and other proprietary rights, of third parties, or the downloading, copying or use of which is subject to additional terms and conditions, stated or unstated. Oxford Biolabs disclaims any responsibility for any harm resulting from the use by visitors of the Website, or from any downloading by those visitors of content there posted.

Content Posted on Other Websites

We have not reviewed, and cannot review, all of the material, including computer software, made available through the websites and webpages to which trx2.com links, and that link to trx2.com. Oxford BioLabs does not have any control over those non-trx2.com websites and webpages, and is not responsible for their contents or their use. By linking to a non-trx2.com website or webpage, Oxford BioLabs does not represent or imply that it endorses such website or webpage. You are responsible for taking precautions as necessary to protect yourself and your computer systems from viruses, worms, Trojan horses, and other harmful or destructive content. Oxford BioLabs disclaims any responsibility for any harm resulting from your use of non-trx2.com websites and webpages.
Copyright Infringement and DMCA Policy
As Oxford BioLabs asks others to respect its intellectual property rights, it respects the intellectual property rights of others. If you believe that material located on or linked to by trx2.com violates your copyright, you are encouraged to notify Oxford BioLabs in accordance with standard Digital Millennium Copyright Act (“DMCA”) Policy. Oxford BioLabs will respond to all such notices, including as required or appropriate by removing the infringing material or disabling all links to the infringing material. In the case of a visitor who may infringe or repeatedly infringes the copyrights or other intellectual property rights of Oxford BioLabs or others, Oxford BioLabs may, in its discretion, terminate or deny access to and use of the Website. In the case of such termination, Oxford BioLabs will have no obligation to provide a refund of any amounts previously paid to Oxford BioLabs.

Release and Consent to Use Submitted Content, Photographs or other Media

As Consideration for participating in the TRX2 “Get-Involved” program (Submit Idea/Submit Story or by submitting content via email or post) you hereby consent to allow your content submitted (including text, testimonials, photos, videos etc.) to be used in both this specific webpage and any future medium with regard to TRX2 or Oxford BioLabs Ltd. brand products, and irrevocably grant to Oxford BioLabs Ltd., its successors, licensees, assignees and affiliated entities (collectively “you”) the right to make, use, reuse, reproduce, modify, publish, republish and create derivative works of this content and/or media content in any and all media now known or hereafter devised, worldwide, in perpetuity for any purpose.This program will deal with selected personal content (Ideas, Stories, etc.) and/or actual media content and may include, but will not be limited to, distribution on the worldwide web, television, DVD, video, electronic, direct TV and radio and print advertisements, box insets, brochures, sales collateral, etc. (all “Media”).
You hereby exclusively grant, assign and convey all right, title and interest, including any moral rights, in your personal idea and/or story and/or photographs/media content and/or any use, reuse, reproduction, modification, publication, republication and creation of derivative works from your personal content and photographs to you. You hereby release, discharge and agree to hold harmless you, your representatives, employees, officers, directors, agents or any person or persons, corporation or corporations, acting under your direction, including any firm publishing or distributing the finished product, even though the finished product may either intentionally or otherwise subject you to scandal, ridicule, reproach, scorn or indignity.
You hereby waive any right to inspect or approve the form of such materials bearing your name, likeness, and/or biographical information, and hereby state:
That all advertisements, copies of advertisements, box inserts, and/or future promotional print applications will be the property of Oxford BioLabs and shall be assigned to Oxford BioLabs.
That all copyright and other proprietary interests of whatever kind in the works acquired shall be the exclusive property of Oxford BioLabs.
That you shall cooperate fully by executing all necessary documents to perfect and register or, if necessary, assign copyright for the exclusive benefit of Oxford BioLabs.
If applicable, you warrant that the text and/or media content you have sent are a true, un-retouched representation of your likeness and that any perceived benefit demonstrated is real and attributed to the Oxford BioLabs product(s) (the “Product”). Similarly, any testimony given is truthful and from my personal experience with the Product(s).  I further understand that by agreeing to this Release and Consent to use, you specifically waive any claim, which you may have for payment or remuneration of any kind.  You hereby warrant that you are eighteen (18) years of age or older, and are competent to contract in your own name.This Release constitutes the complete understanding between the parties and supersedes all prior agreements, negotiations, and discussions between the parties.  No other promise or agreements shall be binding unless signed by both parties.  You have read the foregoing Release and Consent to Use before agreeing to this agreement, and warrant that you fully understand the contents thereof.

Intellectual Property

This Agreement does not transfer from Oxford BioLabs to you any Oxford BioLabs or third party intellectual property, and all right, title and interest in and to such property will remain (as between the parties) solely with Oxford BioLabs. Oxford BioLabs, trx2.com, and all other trademarks, service marks, graphics and logos used in connection with trx2.com, or the Website are trademarks or registered trademarks of Oxford BioLabs or Oxford BioLabs’ licensors. Other trademarks, service marks, graphics and logos used in connection with the Website may be the trademarks of other third parties. Your use of the Website grants you no right or license to reproduce or otherwise use any Oxford BioLabs or third-party trademarks. You hereby grant Oxford BioLabs an irrevocable, perpetual, non-exclusive, transferable, fully paid, worldwide license (with the right to sublicense) to (a) use, copy, publish, stream, store, retain, publicly perform or display, transmit, scan, reformat, modify, edit, frame, translate, excerpt, adapt, create derivative works and distribute (through multiple tiers), any Content you post on or in connection with the Website or Oxford BioLabs services or the promotion thereof and (b) to use your name, likeness and image for any purpose, including commercial or advertising, each of (a) and (b) on or in connection with Oxford BioLabs or the promotion thereof.

Changes

Oxford BioLabs Ltd. reserves the right, at its sole discretion, to modify or replace any part of this Agreement. It is your responsibility to check this Agreement periodically for changes. Your continued use of or access to the Website following the posting of any changes to this Agreement constitutes acceptance of those changes. Oxford BioLabs may also, in the future, offer new services and/or features through the Website (including, the release of articles and resources). Such new features and/or services shall be subject to the terms and conditions of this Agreement.

Termination

Oxford BioLabs may terminate your access to all or any part of the Website at any time, with or without cause, with or without notice, effective immediately. If you wish to terminate this Agreement, you may simply discontinue using the Website. All provisions of this Agreement which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

Disclaimer of Warranties

The Website is provided “as is”. Oxford BioLabs and its suppliers and licensors hereby disclaim all warranties of any kind, express or implied, including, without limitation, the warranties of merchantability, fitness for a particular purpose and non-infringement. Neither Oxford BioLabs nor its suppliers and licensors, makes any warranty that the Website will be error free or that access thereto will be continuous or uninterrupted. You understand that you download from, or otherwise obtain content or services through, the Website at your own discretion and risk.

Limitation of Liability

In no event will Oxford BioLabs, or its suppliers or licensors, be liable with respect to any subject matter of this agreement under any contract, negligence, strict liability or other legal or equitable theory for: (i) any special, incidental or consequential damages; (ii) the cost of procurement or substitute products or services; (iii) for interruption of use or loss or corruption of data; or (iv) for any amounts that exceed the fees paid by you to Oxford BioLabs under this agreement during the twelve (12) month period prior to the cause of action. Oxford BioLabs shall have no liability for any failure or delay due to matters beyond their reasonable control. The foregoing shall not apply to the extent prohibited by applicable law.

General Representation and Warranty

You represent and warrant that (i) your use of the Website will be in strict accordance with Oxford BioLabs, with this Agreement and with all applicable laws and regulations (including without limitation any local laws or regulations in your country, state, city, or other governmental area, regarding online conduct and acceptable content, and including all applicable laws regarding the transmission of technical data exported from the United States or the country in which you reside) and (ii) your use of the Website will not infringe or misappropriate the intellectual property rights of any third party.

Indemnification

You agree to indemnify and hold harmless Oxford BioLabs Ltd., its contractors, and its licensors, and their respective directors, officers, employees and agents from and against any and all claims and expenses, including attorneys’ fees, arising out of your use of the Website, including but not limited to out of your violation this Agreement.

Privacy

Registration data and certain other information about you are subject to our Privacy Policy. Please read the Privacy Policy for information on how your personal data and other information about you will be handled. By accepting these Terms of Use you are also accepting the terms of the Privacy Policy, which is incorporated herein by reference for all purposes.

Delivery Policy

Please read the Delivery Policy for information.

Return and Refund Policy

Please read the Return and Refund Policy for information.

Miscellaneous

This Agreement constitutes the entire agreement between Oxford BioLabs Ltd. and you concerning the subject matter hereof, and they may only be modified by a written amendment signed by an authorized executive of Oxford BioLabs Ltd., or by the posting by Oxford BioLabs Ltd. of a revised version. Except to the extent applicable law, if any, provides otherwise, this Agreement, any access to or use of the Website will be governed by and construed in accordance with the laws of England. If any part of this Agreement is held invalid or unenforceable, that part will be construed to reflect the parties’ original intent, and the remaining portions will remain in full force and effect. A waiver by either party of any term or condition of this Agreement or any breach thereof, in any one instance, will not waive such term or condition or any subsequent breach thereof. You may assign your rights under this Agreement to any party that consents to, and agrees to be bound by, its terms and conditions; Oxford BioLabs Ltd. may assign its rights under this Agreement without condition. This Agreement will be binding upon and will inure to the benefit of the parties, their successors and permitted assigns.

Disclaimer

All material and information presented by Oxford Biolabs on this website is intended to be used for educational and informational purposes only. The statements made about products have not been evaluated by any governmental agency including the Food and Drug Administration. The information on this website is general in nature and is not intended to substitute for the advice provided by your own doctor/physician or other healthcare professional and is not intended to treat, cure or prevent any condition or disease. Please consult with your own doctor/physician or healthcare practitioner regarding the suggestions and recommendations made by Oxford Biolabs through this website.

 

If you suspect you have a disease or health-related condition of any kind, you should contact your healthcare professional immediately. Please read all products' packaging carefully and consult with a healthcare professional before starting any diet, exercise, and supplementation or medication programme. Each person is different, and the way someone reacts to a particular product may be significantly different from another. Oxford Biolabs shall have no liability to you as a publisher of information, or seller of any products or vendor services, including, without limitation, any liability for any defective products.

Oxford Biolabs makes no warranty of any kind, express or implied, with respect to (a) the operation of this website, or (b) products, information or services displayed or sold on this website including any warranty of merchantability or fitness for a particular purpose Oxford Biolabs is providing this site and its contents on an "as is" basis and makes no representations or warranties of any kind with respect to this or its contents.

Under no circumstances, including, but not limited to negligence, shall Oxford Biolabs, its subsidiaries or affiliates be liable for any direct, indirect, special, incidental or consequential damages, arising out of the use, or the inability to use, the materials published on this website. We do not warrant and shall have no liability regarding information provided in this site regarding recommendations for supplements for any and all health purposes. As is clearly stated, this information is provided solely as information for our customers to use when discussing a regimen with their healthcare practitioners.

Except as specifically stated on this site, neither Oxford Biolabs, its subsidiaries or affiliates, nor any of their directors, employees or other representatives will be liable for damages arising out of or in connection with the use of this website. This is a comprehensive limitation of liability that applies to all damages of any kind, including (without limitation) compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property and claims of third parties. Oxford Biolabs liability to you shall in no event exceed the amount of the products in dispute.

We will try to place the proper warnings and product interactions throughout this website, but inevitably we will fail to cover all subject matter. Each person is different, and the way someone reacts to a particular product may be significantly different from another. You should always speak with a healthcare practitioner before taking any dietary, nutritional or herbal supplement.

We do not make any claims to the effectiveness of the products contained in this website. If you have an acute or chronic problem, please see a professional healthcare practitioner.

It cannot be stressed enough that no one should attempt to self-treat based on information on this website. All material provided is for educational purposes only.

Consult your own physician, other healthcare practitioner regarding the treatment of any medical condition. The information on this website is not a replacement for a thorough consultation and examination from a licensed healthcare professional.

All links provided in this website are listed in good faith. You are advised to treat all of this information with caution and common sense.

Users may not post, distribute or otherwise publish on or through the website, any content that violates or infringes any national or international professional or business codes, copyright, trademark trade secret, patent, intellectual property, or statutory, common law or other proprietary rights of others including any party's privacy right or right of publicity is libellous, slanderous, inaccurate, harmful, abusive, threatening, unprofessional, obscene, sexually explicit or pornographic or contains any solicitations of funds or unsolicited mail.

The information provided here is not meant to replace sound medical advice. It is by no means conclusive, and does not guarantee results. It is not meant to take the place of medical treatment, or to be used as a prescription for a remedy of disease.

No persons associated with Oxford Biolabs will be held liable or responsible for any form of use or misuse of any product, whether the information was gathered from this website or not.

YOU SHOULD CONSULT WITH A HEALTHCARE PROFESSIONAL BEFORE STARTING ANY DIET, EXERCISE, AND SUPPLEMENT MEDICATION PROGRAM.

Returns Policy

Oxford Biolabs Ltd (“Oxford Biolabs” – the company behind TRX2®) is committed to ensuring satisfaction for all customers who purchase its products. 

Oxford Biolabs Returns Policy

Our returns policy for all Oxford Biolabs products is as follows:
Oxford Biolabs will, at its discretion, allow for the return or replacement of any unopened and unused product within 60 days from the date of purchase. For products bought under an auto-delivery programme, returns for more than one payment may be provided if requested within the standard 60-day return period.
 
If you decide to return an order for any reason, your credit card account will be fully credited for the amount of the purchase (excluding shipping and minus a handling charge of EUR 5.50).
E-mail [email protected] to obtain a Return Merchandise Authorisation form. Unless otherwise indicated on the invoice you received with your package, return the bottle(s) with the unopened, unused contents to:
 

For non-USA customers

(All countries excluding the USA):

Oxford Biolabs Ltd.
℅  Mailcom AG 
Lise-Meitner-Str.4 
82216 Maisach 
Germany

OR

Oxford Biolabs Ltd.

℅ PickPackDespatch Ltd

Unit 5, Mead Park

Thorpe Mead, Banbury

OX16 4RY, UK

 

For USA customers only:

Oxford Biolabs USA LLC 

Specialty Fulfillment Center Inc

3 - 17th Avenue South

Nampa, ID 83651

USA 

 

You will have to pay for the return shipping postage yourself. If a parcel reaches us without sufficient postage we will have to deduct this from the refund.
Please keep the tracking number of the parcel in case the parcel is lost. We strongly advise to make any returns via a shipment method where you receive such a tracking number as we otherwise won’t be able to acknowledge the receipt of your parcel.
 

Defining Returns and Cancellations

When a customer reaches us by e-mail, our first response is to assist in getting technical support or customer service for the customer for the product that they purchased. However, in some cases a product may be unsatisfactory to the customer for reasons completely beyond our control, in which case a return or a cancellation may be processed.
If a customer requests a return, the money for the requested transaction is refunded back to the customer. If the return is for a product bought under an auto-delivery programme, then the returns policy allows for the most recent payment to be returned. Multiple payment returns can be provided as long as they are within Oxford Biolabs Returns Policy. A return on a product bought as part of an auto-delivery programme will also result in a cancellation.
If customers request a cancellation for an auto-delivery programme, no future charges will be made to their account. A cancellation will not generate a return – it will only stop any future deliveries.

Details of the Oxford Biolabs Returns Policy

Customers requesting a return after 60 days will be directed where applicable to the vendor for technical support or customer service. Vendors may request a return, on behalf of customers, of any purchase up to 60 days after the date of the customer’s purchase.
Returns will only be credited back to the account used to make the original purchase. If the original account has been closed, the purchase is not eligible for return.
As soon as a sale is returned to our return address, the customer receives a 100% refund of the product costs.

Please note: For our physical products we can only refund you for unopened and unused products. Products that have been opened or used are excluded from our refund policy. Please be advised that the breaking of a seal used on the outer packaging of our products shall be regarded as that the products have been opened.

Payouts from that sale are debited back out of the corresponding vendor and affiliate accounts.

Our vendors are not permitted to make any guarantee that conflicts with our return policy. If you find a product sold through websites with any warranty that conflicts with our return policy, please bring it to our attention so that we can take corrective action.
 

Reasons Why a Sale May Be Refunded

Oxford Biolabs has every incentive to keep customers happy by providing quality products and service. To ensure customer satisfaction, Oxford Biolabs reserves the right to reverse a sale, including but not limited to the following instances:
 
- If the customer provides a valid reason for requesting a return within 60 days of purchase;
- If the vendor of the product requests a return on the customer’s behalf within 60 days of purchase if our customer service team confirms there is a valid reason for the return;
- If the customer provides a valid report that the charge was fraudulent or unauthorized;
- In order to comply with credit card industry rules, ACH industry rules, PayPal terms of service, prevailing legislation, and requests from prevailing judicial or law enforcement agents; or
- For any other reason TRX2® deems appropriate.

Oxford Biolabs Cancellation Policy

A customer may cancel an auto-delivery programme at any time. A cancellation means that no future charges will be made to the customer’s account. The cancellation of an auto-delivery programme does not generate a refund.

Abuse of the Returns Policy

Customers requesting serial or repeated returns may be blocked from making further purchases.

Note to Oxford Biolabs Customers

The Return Policy and the Cancellation Policy are part of, and incorporated within, the Oxford Biolabs' Terms of Service. As a condition of registering with Oxford Biolabs and using the Oxford Biolabs Services, you expressly acknowledge that you have read and understood the Oxford Biolabs Returns Policy and Oxford Biolabs Cancellation Policy and you agree to be bound by the terms and conditions contained within. If at any time you disagree with the Oxford Biolabs Returns Policy and/or Oxford Biolabs Cancellation Policy or any part of it, your sole remedy is to cease all use of the Oxford Biolabs Services and terminate your account. Please note, however, that any transactions, which occurred prior to the date of such termination, shall be governed and controlled in full by the terms of this Oxford Biolabs Returns Policy and Oxford Biolabs Cancellation Policy.

Common Questions

Is TRX2® appropriate for children?

We don’t have any data on children, and we only knowingly sell our products to adults.

We recommend customers to consult with their personal doctor/healthcare professional about whether TRX2® is suitable for their children.

Can women experiencing hair loss/thinning use TRX2® as well as men?

Yes, TRX2® is for both women and men. You should be able to expect your first positive results after around 5 months, depending on your metabolism and individual circumstances.

We recognise that hair loss can be a very detrimental condition for many patients, for both women and men. Those who invest their time and money into our products expect results, and we do not take this responsibility lightly.

Currently, one of the most common treatments for women with androgenetic alopecia is Women’s 2% Minoxidil. Although the use of Minoxidil is widespread, there are a lot of female users who are left unsatisfied with the results they achieve. As a potassium-ion channel opener, TRX2® stimulates the same pathways as Minoxidil, and the two treatments often have a synergistic affect. Therefore, women with significant hair loss can consider using both products simultaneously.

Although we cannot guarantee that all of the hair will grow back, we are confident that TRX2® (with or without Minoxidil) will improve the current condition to a noticeable degree. Fighting hair loss requires a multi-faceted approach that stimulates the formation of new hair follicles, increases the diameter of existing follicles, and prolongs the anagen phase of hair shafts (reducing shedding and fallout).

By restoring the function of potassium-ion channels within hair follicles, TRX2® supplementation accomplishes many of these goals. Because our product uses natural ingredients and it does not rely on the elimination of androgens, it is effective in women and it is safe for long-term use.

What will future TRX2® products address?

Our researchers, along with several other members of the scientific community, have demonstrated that as people experience hair loss the function of potassium channels within hair follicles diminishes. The effect is impaired membrane potential and interrupted ion transportation across the hair follicle’s cellular membranes – resulting in shrinking follicles and thinning hair.

TRX2® Molecular Food Supplement for Hair addresses this phenomenon, but yet may be unable to restore thick, terminal hair growth to customers with severe hair loss (Norwood 5-7). Therefore, although the launch of our first products utilising our proprietary technology is extremely exciting for us, we’re not done yet. Oxford Biolabs has an ongoing programme of pre-clinical and clinical research focused towards refining our understanding of the molecular mechanisms behind hair loss and, ultimately, developing a cure.

Please refer to our TRX2® Research page for details on past and ongoing studies.

What do regulatory agencies, such as the FDA and FSA, advise with regard to evaluating and buying dietary supplements

The United States Food and Drug Administration (FDA) offers “Tips for Dietary Supplement Users” at: 

http://www.fda.gov/food/dietarysupplements/usingdietarysupplements/ucm110567.htm

The United Kingdom Food Standards Agency provides free consumer information at:   

http://www.food.gov.uk/safereating/chemsafe/supplements/consumer/

Are your food supplements approved by any regulatory agency such as the FDA, the MHRA or the European Food Standard Agency?

Our food supplements are a non-prescription food supplement products. They are therefore sold in accordance with major international food directives, such as the EC (European Community) Food Supplements Directive 2002/46/EC and the Dietary Supplement Health and Education Act, passed by the United States Congress in 1994. This Act, for instance, allows marketing of dietary supplements without prior approval by the U. S. Food and Drug Administration (FDA). However, the FDA still exerts general oversight over product safety and supervises the marketing claims made for dietary supplements.

Why do you recommend taking TRX2® Molecular Food Supplement for Hair with meals?

We recommend taking TRX2 ® Molecular Food Supplement for Hair with meals as occasionally customers have reported an upset stomach when ingesting the supplement without food. TRX2 ® Molecular Food Supplement for Hair is absorbed more efficiently into the bloodstream when taken together with food.

Can we see before and after photos for TRX2® Molecular Food Supplement for Hair?

We have released the research study that documents the progress of our active participants and it is posted on our website: http://oxfordbiolabs.com/oxford-research/trx2-hair-supplement-clinical-study-results    

Do you have plans on selling your products outside your online store?

To get a list of physical locations that sell our products, please e-mail us at [email protected] and provide us with your city, province and country.

Should I take TRX2® Molecular Food Supplement for Hair in the morning or in the evening, when is the best time?

It doesn’t really make a difference at which time of the day you take TRX2®. However, it is important to take it together with food in order to increase the body’s absorption of the ingredients contained in TRX2®. Most customers choose to take TRX2® during breakfast. Others prefer to split up the 3 capsules across the day (e.g. 2 in the morning and 1 in the evening).

Ultimately, the best time for taking TRX2® is totally up to you and best results, depending on your metabolism, may be different from customer to customer. 

What does “chronic medication” mean?

“Chronic medication” refers to any prescription drugs a customer may use. We are legally bound to advise our customers to always disclose any dietary changes to their doctor or healthcare professional when on chronic medication. This is good practice as well as in your own interest (for example if your chronic condition is connected to any dietary issues).

At what age should one start taking TRX2® Molecular Food Supplement for Hair?

TRX2® is beneficial for all age groups. We tested our supplement in a variety of patient groups, but found it was most effective for those patients with Norwood Hair Loss Patterns 1-4 (shown here: http://www.americanhairloss.org/men_hair_loss/the_norwood_scale.asp).

Young men who are just beginning to lose their hair will see minimal regrowth (because only a minimal amount of hair has been lost); however, they can expect their hair shedding to decrease and their hair volume to increase. Middle-aged men will see similar benefits, although those with very extensive hair loss (Norwood Patterns 5-7) will not be able to regrow all of their hair. Nonetheless, our product has been administered to older males with noticeable hair loss and the results have been quite good.

Can we see your clinical trials results?

All our studies are published on our website as and when they are fully conducted and analysed. For more information please refer to http://oxfordbiolabs.com/oxford-research

How many capsules per day should I take?

One bottle which contains 90 capsules will last 30 days (taking three capsules a day is the recommended quantity). It takes most patients about 5 months (5 bottles) to see results, but some patients report results in as little as three months (for others it takes longer). This discrepancy is largely dependent on a person’s metabolism and genetic predisposition.

Some customers increase the quantity to 4 capsules per day and report an improved efficacy compared to the recommended quantity. However, all our data is based on the dose of 3 capsules per day – there should be no need to increase the quantity (unless you are overweight or have a large body weight).

Some customers, especially those with a light body weight or those sensitive to one of TRX2®’s ingredients (e.g. Niacin), decrease the quantity to 2 capsules per day without compromising on efficacy. 

TRX2® and hair dyes

Hair dyes, especially permanent ones, have a side effect of hair loss due to the abrasive and damaging chemical ingredients they contain, e.g. ammonia and peroxide. One of the factors is also misuse or overuse of hair dye treatments, e.g. leaving dye on too long or mixing the formula incorrectly, so following directions is important.

Semi-permanent hair dye has fewer chemicals and has no ammonia. Henna hair dye is highly recommended as a good alternative since it contains all natural ingredients.

As long as the hair follicles haven’t been damaged underneath the scalp, new healthy hair should return on its own in several months. If the follicles have been severely damaged for some reason, hair regrowth may not be possible.

Shipping & Delivery

General information

At Oxford Biolabs we try to deliver your supplies anytime anywhere.

Save on Shipping

Because international shipping costs are high, you may prefer ordering multiple month supplies at once to save on shipping costs to take advantage of a preferential rates. Free shipping cost is available for each customer and depends on total order value. Please find the up-to-date shipping rates here:

Delivery Options and Times*

International orders are shipped no later than 1 business day after receipt and credit authorisation. We deliver using internationally reputable couriers. Average delivery time is 7 to 10 days. Oxford Biolabs issues shipping confirmation e-mails with tracking numbers to customers who provide an e-mail address.

Please note: Shipping times can significantly vary among the countries; usually 3-8 days for most European Union orders and 8-15 days for most international orders. If you experience any problems with the delivery of your supplies please get in touch with us on help page.

Import Taxes

Customers are responsible for any import taxes, customs duties, sales taxes and any other levies that may be assessed by the local country.

Shipping Restrictions

Customers are responsible for making sure that they are allowed to import our dietary supplement and cosmetic products. If customs in your country returns your order to us for any reason, we will refund to your credit card account the total of your purchase minus twice your shipping charge (because we must pay our carrier the same shipping charge to return the order to us), plus any other charges incurred, such as quarantine or warehousing fees assessed by Customs in your country.

*Due to shipping limitations of pressurised containers with aerosols TRX2 ® Hair Revitalising Foam can be shipped to the following countries: Austria, Belgium, Germany and Luxembourg. 

Multiple Shipping Addresses

To ship to more than one address, please place a separate order for each shipping address.

Customer Service

If you have questions about your order, you may e-mail your enquiry to [email protected] . Customer service hours are as follows:

  • 7 a.m. to 5 p.m. Pacific Time, Monday through Friday.
  • UK (GMT): 7 a.m. - 5 p.m.
  • Europe (CET): 8 a.m. - 6 p.m.

Please add our contact email address [email protected] and [email protected] to your address book/whitelist to avoid that important notifications go to SPAM folder.

The TRX2 Money-Back Guarantee

Oxford Biolabs's 60-day money-back guarantee on unopened and unused product is available to all international customers. If you decide to return an order for any reason, your credit card account will be fully credited for the amount of the purchase (excluding shipping - see details under Shipping Restrictions).

E-mail [email protected] to obtain a Return Merchandise Authorisation form. Unless otherwise indicated on the invoice you received with your package, return the bottle(s) with the unused contents to:

For non-USA customers:

Oxford Biolabs Ltd. 
c/o Mailcom AG 
Lise-Meitner-Str.4 
82216 Maisach 
Germany

OR

Oxford Biolabs Ltd.
℅ PickPackDespatch Ltd
Unit 5, Mead Park
Thorpe Mead, Banbury
OX16 4RY, UK

For USA customers only:

Oxford Biolabs USA LLC
Specialty Fulfillment Center Inc
3 - 17th Avenue South
Nampa, ID 83651
US

I need to change my shipping address…How do I do this?

If you need to change your shipping address, you can log in online through your profile and make the change yourself, but we ask that you please also e-mail us at [email protected] with your new shipping address so that we can confirm it has been updated in our system.

Can you ship my order at a faster rate to me?

Once we receive and process your order, it is then sent to our shipping department. Once they receive the order, it is shipped within 24-48 hours. The destination country will determine how long it will take for you, the customer, to receive the order.

Does “Complete” status mean the product is being shipped already?

“Complete” status means that we have already received your order.You will receive an e-mail notification once your product is already being shipped.

How long before I receive the product?

International orders are shipped no later than 1 business day after receipt and credit card authorisation. Average delivery time is 1 to 2 days (Germany and some UK), 3 to 5 days (UK), 5 to 7 days (European Union excluding Germany and UK), 7 to 10 days (United States, Japan, International – all others). Oxford Biolabs issues shipping confirmation e-mails with tracking numbers to customers who provide an email address. 

Do you deliver to ALL countries?

We will deliver your supplies anytime, anywhere. We ship our products worldwide.

My tracking link doesn’t work? What do I do?

When you place an order for our products, you will receive an e-mail once your order is shipped with a tracking link so that you can follow your package right to your doorstep. If for some reason your tracking link doesn’t work, please contact us at [email protected] and we will get you an updated tracking link right away.

Shipping countries notes

Please refer below to some of the most common issues which you may experience dispatching Oxford Biolabs products to certain country: 

Australia: Customs duties may apply if total value of the order exceeds AUD 1,000.

Brazil: A doctor's prescription may be required by Brazilian Customs to be presented, for Oxford Biolabs' food supplement products into the country.

Chile: Customs duties, VAT and import fees may apply if the total value of the order exceeds approximately USD 30.

China: Customs duties may apply if total value of the order exceeds CNY 1,000.

Denmark: Customs duties, VAT and import fees may apply if total value of the order exceeds DKK 1,150.

Israel: Imports with a CIF value up to USD 1,000 and with a weight up to 30 kg, are exempt from import duty. However, VAT, Purchase Tax, and Import Port Fee may apply. 

Norway: Customs duties may apply if the total value of the order exceeds NOK 350.

Additional customs duties, VAT and import fees applied by customs on importation of orders, shall be borne by the customer.
If you are in any doubt, please ring customer service at one of the numbers listed at Contact Us Page, or e-mail us at [email protected]

Not finding your country?

Not finding your country in the dropdown for the shipping address during checkout? 

Please be assured that we do ship to most countries worldwide. However, Oxford Biolabs operates multiple stores depending upon geographical location, so possibly you have arrived at a store which doesn't support your country's shipping address. We are sorry for the inconvenience, but we would ask you to go to the store, which supports your country, and repeat the order entry detail:

United Kingdom Store (Click here)

North American Store (Click here):

- United States;

International Store (Click here)

- Supports all other countries

Money back guarantee

How can I ask for a refund?

Our products come with an offer of a 60-day money back guarantee. If you are not completely satisfied with the product or if it is causing you any discomfort or other side effects please contact us and return your unused bottle/s. We will refund the purchased price of any unopened and unused bottles.

Auto-Delivery Supersaver Programme

General description

If you subscribe to our Auto-Delivery Supersaver Programme, we will ship a 3-month supply of the products from one of our great package offers to you every 90 days for a combined saving of up to 32%. Also, for any of our future products, you will receive one free sample as soon as available.

Your payment will be charged every 90 days on a recurring basis (usually one day prior to shipping).

There is no minimum time commitment. To cancel or suspend shipments, simply contact Customer Service via  [email protected]  at least 14 days prior to your next scheduled shipping/billing date.

Please keep your credit card and shipping address current. If your information changes, including card expiration, please contact Customer Service to submit the updated information.

I want to skip/schedule next scheduled billing/shipping date

It is possible to skip your next scheduled billing/shipping date in your account. You are also welcome to contact us at [email protected] if you need to set a specific date for the next shipment.

Can I cancel my subscription?

Cancellation of your subscription (i.e. automated shipping/billing every 90 days) is possible and can be done at any time, BUT once cancelled, we will not be able to reverse it and any accrued programme benefits will be lost. The programme is designed for your comfort so that you don’t have to worry about re-ordering and ensures a constant supply of our supplements and other products.

How do I access my programme subscription?

Under the Auto-Delivery Supersaver Programme, automated shipping/billing has been setup. Furthermore, you can log in to your account (or open one in case you haven’t yet done so) to track your order status.

TRX2® and other treatments/supplements

TRX2® supplements and hair transplantation

We can’t give you an advice on when to start TRX2® supplementation after hair transplant.

Please consult with your doctor or healthcare professional.

Can I take TRX2® Molecular Food Supplement for Hair along with vitamin supplements?

Yes. In fact, Oxford Biolabs' Scientific Advisory Board recommends that healthy adults take a multivitamin in addition to their regular TRX2® supplement in order to avoid any vitamin shortages. The following vitamins and minerals have been shown to play a role in hair growth (look for them when choosing a multivitamin product):

Vitamin AVitamin EVitamin B1Vitamin B2Vitamin B3Vitamin B5Vitamin B6Vitamin B12BiotinCopperSilica / Silicious earth

When using TRX2® in combination with a multivitamin please make sure that your total daily intake does not exceed the daily recommended amount of an individual compound or vitamin. Please note that Oxford Biolabs does not promote any specific ingredient, regimen or use, and you should always consult a doctor or healthcare professional if you are not sure about something or when using TRX2® in combination with a prescription medicine or other treatment regimens.

Can I take TRX2® Molecular Food Supplement for Hair with prescription drugs?

According to the US-based Natural Medicines Comprehensive Database (NMCD), L-carnitine (one of the major ingredients in TRX2® Molecular Food Supplement for Hair capsules), can increase the effects of anticoagulants. Customers taking anticoagulants therefore should check with their healthcare professional before embarking upon a regimen that includes TRX2®. With regards to the other ingredients in TRX2® Molecular Food Supplement for Hair, the NMCD recommends that people taking anti-diabetes drugs, people consuming large quantities of alcohol and people who have frequent attacks of gout despite uricosuric therapy should consult their healthcare professional before starting TRX2® supplementation.

Of course, before taking any dietary supplement and prescription drug simultaneously, you should always consult with your doctor or healthcare professional.

If TRX2® is taken with minoxidil would it enhance results? If later I stopped with minoxidil but continued with TRX2® would hair loss start again?

Generally TRX2® is designed to be effective on its own. Hence there is no need to complement it with minoxidil. In fact all our study results are based on patients who have been only used TRX2® and no other treatment – check out http://www.trx2.com/research.

However, customers who have been using minoxidil for years and have experienced a decrease of efficacy over time have experienced enhanced efficacy once they started using TRX2® in combination with another product. Hence, there is no reason why a customer cannot use both if he or she wishes to do so. If, later on, a decision is made to stop taking minoxidil but to continue taking just TRX2®, it is unlikely that there would be negative results. (However, again we have not conducted studies on this – TRX2® is designed to be effective on its own.)

Continuous intake of TRX2® is important as it works together with your metabolism. It is not a cure. Unfortunately, there isn’t a cure yet for androgenetic alopecia (however, we are working hard on this and the majority of our research is focused on this).

Taking anti-depressants with TRX2®

We can only advise you to talk to your doctor or healthcare specialist when combining any new treatment with anti-depressants. Legally, we are not able to give advice.

Storage of food supplements

Where and how should I properly store your food supplements?

We recommend storing food supplements in a dry place and at slightly cooler temperatures, simply because this will reduce oxidation of the ingredients.

TRX2® contains L-Carnitine-L-Tartrate, which may start melting if the temperature is too hot (but this would need to be much higher than 85 Fahrenheit/30 Celsius).

Is it OK to store multiple months’ supply of food supplements in a plastic container?

We recommend keeping your supplies in the glass container provided. There are several reasons for this. The glass bottle, which we provide, protects your supplies from oxidation as well as UV light radiation. Furthermore, the glass container has an originality seal – this way you can be absolutely sure of the high quality characteristics of the product. We cannot guarantee the noted expiration date, if supplies are not kept in the glass container.

Side effects

Are your food supplements safe for those who are allergic to gluten and dairy products?

As indicated, all ingredients of our food supplements are of naturally-based and produced at the highest standards of quality. The product should not contain any gluten and/or dairy fats. Also, please note that our company cannot advise you on any individual health related issues and therefore cannot take any responsibility for possible side effects when taking our food supplements. If there is any doubt, please consult your doctor and/or healthcare professional.

Are there known side effects from taking your products?

Our food supplements contain only naturally-based ingredients and therefore side effects and cross-interactions (e.g. with medications) are minimal.A very small number of customers experience an upset stomach but this can be avoided if you take our food supplements with your largest meal of the day.Please, note, we can’t advise you in medical terms. We advise consumers to consult a doctor or healthcare professional before changing their diet to include our food supplements, especially if they are on a special diet and/or take other medications (e.g. against hypertension, diabetes, etc.).

Does TRX2® cause shedding of hair?

Most patients do not report shedding as a side effect when using our supplement. Still, in some instances shedding may occur if TRX2® is being used in conjunction with treatments such as minoxidil (Rogaine). If shedding does occur, you can expect your hair to re-grow during the normal course of treatment.

Mild shedding is common when starting many new hair loss products, although it is not usually reported with TRX2®. Overall, shedding means that miniaturised hairs are starting a new cycle. If this was stimulated due to TRX2®, you can expect the hairs (when they grow back and re-cycle) to become thicker and stronger.

Shedding can be a normal part of your hair cycle (many people report increased shedding during wintertime, springtime, etc.) and should not be permanent. If your shedding becomes worse, you should always contact your personal doctor/physician.

Can TRX2® grow body hair?

Based on our studies performed to date and based on the customer experiences we have gathered so far, there shouldn’t be any extensive hair growth on body parts other than your head. The ingredients in TRX2® are suppose to act on a highly specific form of potassium ion channels (called SUR1) that are only supposed to be present in human head hair follicles, and therefore would weaken the argument that excessive hair growth occurs in body parts other than your head.

Download Centre

TRX2® Molecular Food Supplement for Hair – Product Information Brochure

TRX2® Molecular Food Supplement for Hair – Customer Information leaflet

TRX2® Hair Revitalising Foam – Customer Information leaflet

TRX2® Hair Revitalising Lotion – Customer Information leaflet

TRX2® Molecular Food Supplement for Hair – Multilingual Customer Information Booklet

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