Personalized Medicine, LLC NutriLiv website and mobile app privacy policy

Effective September 7, 2024

Important Information

At Personalized Medicine, LLC, we are dedicated to supporting your wellness journey and believe in transparency regarding how we handle the data you share with us throughout this process. Our Services encompass both the NutriLiv.app website ("Website") and NutriLiv mobile applications ("Mobile App"), collectively referred to as the "Services" in this Privacy Policy. We strongly recommend reviewing both this Privacy Policy and our terms and conditions of use (hereinafter "Terms").

USING OUR SERVICES INDICATES YOUR AGREEMENT TO THE COLLECTION, USE, AND PROCESSING OF YOUR PERSONAL DATA IN THE UNITED STATES AS DETAILED IN THIS PRIVACY POLICY.

Our platform and infrastructure, including all user accounts and NutriLiv functionality, are hosted on US-based servers. For users who access our platform from countries outside the US: Please be aware that any data we gather (including cookies and device-specific information) will be maintained and handled on servers within the United States. The data privacy regulations and protections in the US may vary from those in your location, which could mean different user rights and security measures than you're accustomed to. By utilizing our platform and submitting your information, you acknowledge and agree to your data being transferred to and processed in the United States. This consent serves as our legal foundation for international data handling, except where this Privacy Policy explicitly states otherwise. The account setup process may include steps to formally confirm your agreement to these international data practices.

By continuing to access and engage with our platform and Services, you confirm that you have read, comprehended, and agreed to all conditions set forth in this Privacy Policy. If you find any aspect of this Privacy Policy or our Terms unacceptable, please stop using our Services immediately and do not provide any Personal Information (as described below) through our platform.

Notice for European Union Residents: We have designed this Privacy Policy to meet the requirements of the EU's General Data Protection Regulation (GDPR), detailing our lawful basis for Personal Data processing and including mandatory GDPR disclosures for users and customers in Europe. For more detailed information relevant to European users, please refer to our regional privacy notices section.

Information About Your Personal Data

This Privacy Policy governs information about you, your device usage, and how you engage with our Services.

'Personal Data' refers to any information that identifies you or could reasonably be used to identify you, whether independently or in combination with other details. Examples include your full name, email contact, telephone number, device identifiers, specific cookie and network markers, and 'Wellness Data.'

As detailed throughout this Privacy Policy, NutriLiv processes and handles Personal Data for several purposes, including: enhancing and maintaining our Services, conducting business operations, delivering marketing and promotional content, and providing innovative wellness solutions.

We reserve the right to convert Personal Data into anonymous or de-identified information by removing identifying elements (like names, email addresses, or traceable identifiers), applying masking techniques, or using other appropriate methods. Once anonymized or de-identified, the use of such data falls outside the scope of this Privacy Policy.

How We Collect and Use Personal Data

We collect your Personal Data in a number of ways and for various purposes, including:

1. When you register for an account or interact with our Services

Your use of our Services triggers the collection of Personal Data at various touchpoints, such as account registration, Premium Subscription enrollment (including transaction processing), general platform usage (including content browsing), and Service customization requests. This information typically includes identifiers such as your name, profile photo, login credentials, email address, and broad location information.

2. When you input Wellness Data within our Services

“Wellness Data” includes data related to items you record consuming and general information about your wellness goals. We collect this data in order to provide the Services.

3. When you communicate with us or sign up for promotional materials

We collect Personal Data whenever you engage in direct communications with us or subscribe to receive marketing materials and updates ('Messages') through email and push notification channels.

When you provide consent to receive Messages, we may leverage your Personal Data and associated information to send you updates regarding the NutriLiv Services you've accessed or purchased; deliver marketing materials and personalized advertisements; inform you about platform features; announce contests, challenges, sweepstakes, and other special offerings ('Promotions'); suggest Services that match your interests; and conduct other marketing activities. Your communication preferences can be managed directly through your account settings.

Please note that regardless of your email settings, we may send you Messages pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to Services you have purchased or use.

We may use your Personal Data to respond to and address your requests for technical support, questions or complaints about the Services, or any other communication you initiate. This includes accessing your account to address technical support requests.

4. When you participate in special activities, offers, or programs

We collect Personal Data, including Wellness Data, when you choose to participate in Promotions, surveys, or research activities and initiatives ('Research'). This may include basic information such as your name, mailing address, email contact, phone number, and age, along with other details necessary for Research participation. For Promotion winners, additional information like tax documentation, waivers, and releases may be required depending on the prize type.

Our surveys may explore various topics, ranging from Personal Data collection to understanding your brand and product preferences. These Promotions or surveys might be conducted by NutriLiv's service providers or in partnership with other businesses. In these cases, Personal Data may be collected by and/or shared between NutriLiv, the service provider, and/or business partner, including for marketing purposes. When a specific Promotion or survey handles your Personal Data differently than outlined in this Privacy Policy, you will be informed of the applicable privacy policy governing that particular data collection at the time of participation.

5. When you engage with our online communities or advertising

We collect Personal Data when you interact with our digital communities. This includes your engagement with advertisements, interactions on our social media platforms, content submissions, and any information you provide in comment sections, blogs, or community forums sponsored by or linked to NutriLiv. Since our community forums are visible to the public, we encourage you to carefully consider what information and content you choose to share.

6. When you access third party products and services

Through our Services, you may have the opportunity to register for and purchase products and services from third parties, or interact with other websites, mobile applications, or online locations (together, 'Third Party Sites'). When you share Personal Data with Third Party Sites through our Services, we may collect this information. In such cases, we will provide you with additional information about how we use your Personal Data.

7. When you connect with us through social media

When you opt to enable, log into, or access our Services through social media or social networking platforms, such as Facebook (referred to as 'Social Networking Service' or 'SNS'), we may gather Personal Data that you've previously provided to that SNS. For instance, when you use your Facebook credentials to log in, with your permission, we may collect Personal Data from your Facebook profile as allowed under Facebook's Terms of Service - including details like your email address, profile picture, and list of friends. We utilize this information to deliver, improve, and customize our Services (for example, to help you connect with or receive friend suggestions within our Services). Should you wish to restrict this data sharing, you'll need to modify the privacy settings within your SNS account.

8. When we collect data from third parties or publicly-available sources

We may acquire certain information about you from external sources to enhance our Services and refine our marketing and advertising efforts. Your Personal Data may be combined with information gathered through our Services, from other users, or from third parties to improve your experience and strengthen our Services.

9. When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies

We collect Personal Data through various technologies including cookies, web beacons, device identifiers, advertising IDs, geolocation tracking, HTML5 local storage, Flash cookies, and IP addresses. Our browser cookies serve multiple purposes, including essential functionality cookies, personalization cookies, performance/analytics cookies, and advertising cookies. For more details about our use of cookies and device IDs, including options to control or opt out of certain data collection or usage, please refer to our cookie and device ID section.

10. When we aggregate or centralize data

We aggregate and centralize Personal Data and Wellness Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.

11. When we provide you geographically relevant Services, offers, or advertising

We may use general location data to provide you with Services, offers or advertising that are relevant to your general location.

12. When you ask us to customize our Services

We use photos, videos, or other data you provide to us to customize our Services.

13. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes (location-specific disclosures may apply)

We may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

How We Disclose Personal Data

We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy, in the Location-Specific Disclosures section, and in the following ways:

1. Operation and Improvement of Services and User Experience

Internally to relevant departments within NutriLiv, in order to provide and improve Services, for marketing purposes, and for advertising.

2. To Service Providers and Vendors

With business partners, marketing partners, and vendors to provide, improve, and personalize the Services.

Notice for Apple Users

For Apple users, our iOS mobile apps share personal data with third parties as described in this Privacy Policy. We take measures to ensure such third parties provide privacy protections identical to or equal to those required under this Privacy Policy and apple’s developer guidelines.

3. To Social Network Providers

With social network providers when we use social network widgets, buttons, or plug-ins in our Services.

4. For Advertising and Marketing

With advertising and marketing partners for advertising and marketing purposes on NutriLiv’s behalf and on behalf of third parties, including but not limited to Facebook.

5. For Certain Analytics and Improvement

With certain companies for purposes of analytics and improvement of the Services.

6. For Interest-Based Advertising

With companies involved in interest-based advertising, including web, mobile app and other advertising. This advertising consists of NutriLiv and third party ads that are personalized and displayed on our sites and apps and through other channels. For more information on how data is disclosed for advertising see interest-based advertising.

7. For Legal Compliance, Law Enforcement, and Public Safety Purposes (location-specific disclosures may apply)

With law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

8. In the event of an actual or contemplated sale. (location-specific disclosures may apply)

We may share data with potential or confirmed buyers, investors, or successor organizations in the context of planned or actual business restructuring, including financing, sales, or other transactions involving the transfer of all or part of our business or assets. This enables necessary due diligence under appropriate data handling and protection assurances.

For European Economic Area residents, our data sharing practices comply with applicable European and national data protection regulations.

Legal Framework for Data Processing This portion explains our legal authority for processing your data if you reside outside the United States (within the United States, consent is typically obtained when you acknowledge this Privacy Policy through website links or mobile applications). Multiple legal bases may apply to certain processing activities depending on circumstances or services offered.

Personalized Medicine, LLC serves as the controller of your Personal Data ('Data Controller') under applicable data protection laws. As Data Controller, we handle your Personal Data in accordance with this Privacy Policy. For questions about your Personal Data processing or this Privacy Policy, please consult our location-specific disclosures for appropriate contact details.

European Union Residents Note: Additional information regarding Legal Basis for processing is available in the EEA location-specific disclosures.

Our collection and processing of your Personal Data serves various purposes outlined in this Privacy Policy. Separate consent isn't always required, including:"

1. For the Performance of a Contract

To meet our contractual obligations in delivering our Services, which includes but is not limited to: creating and maintaining your account, completing your purchases (including payment processing), communicating about Service issues, supporting your use of wearable or connected devices, delivering location-specific Services (including geographically tailored content), enabling friend connections across platforms, facilitating content and achievement sharing, supporting friend invitations, customizing Services as requested, obtaining necessary Personal Data from third-party sources, enabling access to third-party products and services, collecting data from third parties or publicly available sources, and centralizing data for optimal Service performance.

2. To Meet Legal Obligations

To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.

3. For Legitimate Interests

To operate our business and deliver our Services beyond our direct contractual obligations to you, based on NutriLiv's 'legitimate interests' under applicable law - unless these interests are outweighed by rights and freedoms requiring Personal Data protection.

The following activities fall under Legitimate Interests processing, subject to applicable law:

Communication: To maintain contact regarding our Services, including essential updates about terms changes and handling your requests, inquiries, and complaints. Essential communications, including emails, may be sent regardless of other NutriLiv communication preferences. These required communications don't need consent. We also process your Personal Data based on legitimate interests when you contact us, including signing up for promotional materials without explicit consent requests.
Request Management: To handle your technical support needs, online service requests, product information inquiries, or other communications you initiate, including accessing your account for technical support purposes.
Marketing Communications: To deliver promotional messages and personalized marketing using non-sensitive Personal Data when you: communicate with us; opt into promotional offerings; participate in programs; engage with our online communities or ads; require location-based Services or advertising; and through data aggregation and sharing with our service providers.
Survey Distribution: To distribute Service-related surveys, unless commercially focused. Commercial surveys require your prior marketing consent.
Legal Compliance and Safety: To support investigations into potential illegal or improper activities, including information sharing for fraud prevention and crime detection. To protect our rights and property, or third-party rights and safety.
Service Enhancement: To create, provide, improve and enhance our Services and user experience, including: processing non-sensitive Personal Data from wearables and connected devices integrated with our Services; supporting third-party product access; utilizing cookies, device IDs, location data, environmental data, and tracking technologies; enabling social media connectivity; gathering third-party and public data; consolidating information; and sharing data with service providers. Also covers internal research, analytics, innovation, testing, monitoring, communication, risk management, and administration.
Terms Enforcement: To uphold our Terms, Privacy Policy, and third-party agreements.
Business Transitions: (Subject to location-specific disclosures) To facilitate planned or actual business reorganizations, including financing, sales, or asset transfers, enabling necessary due diligence for transaction decisions.

Consent as a Basis for Processing

In certain situations, we will seek your explicit consent to process your Personal Data. You can indicate this consent, as allowed by law, through methods like checking a box (or similar action) when you: (i) submit Personal Data through our Services or forms (including Promotion enrollment) (ii) register for or set up an account with us

Since consent requirements for Personal Data collection and use vary by country, specific consent procedures differ across regions. We may request your consent for various activities including:

1. NutriLiv Marketing and Communication

We may ask for your consent to contact you by email or push notifications about other offers, products, Promotions, or services that we think may be of interest to you and for other marketing purposes.

2. Sharing with Third Party Services

We may also ask for your consent to share your Personal Data with certain Third Party business partners in order to offer certain goods, services, or programs. To withdraw consent, please go to the preferences of the specific third party service or app.

3. Third Party Marketing

We may ask for your consent to provide Personal Data to allow third parties to contact you regarding their products, services, Promotions, or offers. Typically this is in conjunction with a sweepstakes or challenge (your consent for third party marketing is generally not a pre-requisite to participation. To withdraw consent, please go to the preferences of the specific third party.

4. Collecting Mobile Device IDs and Advertising IDs

When you use our Mobile Apps we may ask for your consent to collect these (this consent may be captured at the operating system level). To change your consent status for this data, please go to the preferences of the Mobile App.

5. Processing Sensitive Personal Data

We may request your consent to process sensitive Personal Data. The Website or Mobile App may require this data to provide the Services. If you choose not to provide sensitive Personal Data (for example, specific kinds of Wellness Data), certain features or Services may be unavailable or not function properly.

6. Research

We may request your consent to use your Personal Data for Research purposes. We may also request your consent to contact you to determine your interest to participate in certain Research initiatives and to share identifying results. For market research, we may ask questions on behalf of business partners and share your response with business partners.

7. Advertising

We use cookies, pixels (including email pixels), mobile device and advertising IDs, general location data, Wellness Data, app or service usage data and data from third-party wearables, connected devices or sensors that integrate with our Services for purposes of interest-based and cross-app, cross-device advertising. The consent for which may be managed at the operating system level.

8. Transfer of Data

We transfer data to the United States and to other countries/regions for processing. We may request your consent for this transfer or the transfer, in other cases, may be justified by a legal basis other than consent.

9. Automated Processing

Our Service delivery and recommendations may involve automated processing techniques. Some of this processing is essential to provide certain Services (in fact, sometimes it is the Service itself) and therefore doesn't require consent. Additionally, certain automated processing is considered non-significant based on either the type of data involved or the nature of decisions/recommendations made, thus not requiring consent. However, when automated processing is both significant and involves sensitive Personal Data, we will obtain your consent before sharing or using such data. Regarding automated ad profiling for targeted advertising, you can manage your consent preferences for website services by disabling advertising cookies as detailed in our cookie and device ID usage section. For mobile applications, you can adjust your consent by enabling the Limit Ad Tracking feature or similar options as specified in our cookie and device ID usage section.

10. To Enable Social Sharing and Connect with Us on Social Media

Our Services consist of social sharing and communication with others. If you sign up for these Services, we may ask for your consent to use your information to enable sharing as described in the Service. We may also ask for your consent when you connect with us through Social Media.

11. Promotions

We may ask you for permission to use your Personal Data and Wellness Data for special offers, events, sweepstakes, and other Promotions. We may use the Personal Data we collect during Promotions, to administer the Promotion, verify identity and age, and to communicate with you about the Promotion.

Changing Your Sharing Preferences

Details on how to update your sharing preferences and the default settings for our Services are outlined within the sharing standard.

Note: When you share information from our Services externally with a SNS, the information you post is governed by their privacy policy and settings.

Interest-Based Advertising

Interest-based advertising delivers targeted ads based on your browsing patterns and app usage across multiple websites or apps over time. Our advertising strategy includes developing and implementing 'audience segments.' You maintain the right to limit information usage for interest-based advertising and can choose not to receive such targeted ads. Your location may determine whether we need your consent for using cookies, including advertising cookies. You'll find more details about Audience Segments and interest-based advertising options in the section below.

Audience Segments. We share different types of information to enable interest-based advertising, including third-party targeted advertising. This process involves using Personal Data to create audience segments, which are then used for interest-based advertising, including third-party advertising, across NutriLiv's digital platforms. These audience segments are developed using multiple data sources, including: website activity, app usage patterns, Wellness Data, online and offline purchase history, interactions with our advertisements and marketing emails, similar information types, and in some cases, third-party data.

United States Note: The audience segments are made available for interest-based advertising for third party advertising on the NutriLiv Services.

Interest-Based Advertising Controls and Opt-Out Options. You can choose to prevent your data from being used for interest-based advertising purposes, including third-party advertising and segments, regardless of where these ads appear. To maintain these opt-out preferences, your browser must allow strictly necessary cookies. We align with the Self-Regulatory Principles for Online Behavioral Advertising supported by the digital advertising alliance (US), canadian digital advertising alliance (Canada), and european digital advertising alliance (EU). Residents of these regions can visit ad choices (US), your ad choices (Canada), or your online choices (EU) to opt out of interest-based advertising from participating companies and learn detailed information about how interest-based advertising works. Note that opting out doesn't eliminate advertising from our services or your Internet experience; rather, it means the data we collect from our website won't be used for interest-based advertising, and the ads you see won't be tailored to your interests. Mobile App Users: You can opt out of interest-based advertising on mobile devices by enabling the "Limit Ad Tracking" or equivalent setting on your mobile platform. This sends us and third parties a signal that your data shouldn't be used for interest-based advertising.Our cookie and device id use section provides additional options for controlling the use of particular kinds of cookies, including advertising cookies. You may use our “advertising cookies” toggle in these settings to prohibit the collection and use of Personal Data in cookies for interest-based advertising.

Managing Preferences and Withdrawing Consent

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Collection and use of Personal Data may be required for the Services to work.

We provide you several ways to manage your preferences:

Cookie Use and Controls

Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to personalize your web experience and for security, analytics, marketing, and interest-based advertising. Our cookies are placed and read by our web servers, while other cookies are placed and read by other companies’ web servers. Information on specific cookies is found on our website via the adchoices link. You can block and control cookies using the information noted in this section. If you block all cookies, certain functionality on our Website will not work.

One way to think about cookies is based on their function. The following settings will control our use of browser cookies, the use of IP address for tracking, and the collection and use of data for cookie-based, interest-based advertising.

[ IN ] Required Cookies. These strictly necessary cookies are used for core functionality, and recognize when you are signed in, are necessary for security, and enforce your privacy preferences. Without these cookies, some functionality on our Website may fail. You can block these cookies in your browser preferences.

[ IN / OUT ] Performance and Analytics. These cookies help to improve the Website by allowing us to understand how the Website is used and how the Website performs. These cookies include analytics and measurement.

[ IN / OUT ] Advertising Cookies. These cookies help us and other parties personalize ads that are shown to you on the Services, as well as on other websites. If enabled, these cookies will allow third parties engaged in interest-based advertising on our Website to recognize your browser software on other websites too.

IP Address Use

An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include “public” IP addresses, such as the IP address for a home router that is visible to the Internet, as well as “local” IP addresses, which are IP addresses assigned to computers and mobile devices “behind” a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency.

You can choose not to have IP address used for purposes of advertising or analytics by using the cookie controls for “Advertising Cookies,” and “Performance/Analytics,” above.

Web Pixels or Beacons Use

Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party’s cookies are currently stored in your browser, those cookies will be transmitted with the request. Beacons can be used on web pages for advertising or to confirm the opening of a marketing email. When used in conjunction with cookies for interest-based-advertising, the cookie controls above can be used to control the purpose for which they are used.

HTML5 Local Storage

HTML5 Local Storage in the browser is different from cookies, but can be used for the same purpose (to pair a tracking ID to a particular web server with your web browser so that the web server can identify your web browser over time). You can control the purpose for which HTML5 Local Storage is used by using the cookie controls outlined above.

Social Network Interaction and Widgets

Social network widgets, buttons, and plug-ins on our Website passively transmit data regarding a social network’s members to that social network, even when a button is not clicked. These technologies may allow a social network (e.g., Facebook) to personally identify its members and to know the web pages its members have visited. This is true wherever social network buttons are embedded, regardless of whether a button is “clicked” or “pressed.” If you belong to a social network or use these categories of web services, you should review the privacy policies of those services to understand the nature of the data that they collect and what, if any, options the service offers to control how data is collected and used. If you disable advertising cookies, the passive tracking associated with these buttons will be blocked on our sites.

Mobile Device Advertising IDs, Location, Sensor Data, and In-Range Device Data Use

Our Services may transmit Device IDs, general location data, and data from sensors to us and our partners, including our advertising partners.

Device IDs include IDs associated with your mobile device carrier such as IMEI, MEID, IMSI; platform-specific IDs such as Android ID, Google AID, and Apple’s IDFA; and IDs that are part of your device hardware, such as WiFi MAC address, and serial number. Exactly which Device IDs are transmitted can depend on your mobile device platform and the version of your operating system.
General Location Data. Our Services may transmit general location data. General location data may be obtained from GPS services, cell tower triangulation, or known location of nearby WiFi access points.
How We Use Mobile Device Data. We may use Device IDs, coarse location and general location data, and data from sensors, including the local network, (together with app usage data and Wellness Data) for strictly necessary purposes; improving our apps and analytics; personalization and preferences; and cross-app, cross-device, interest-based advertising.

Withdraw Your Consent for Use of Your Mobile Device IDs for Analytics and Advertising

Activating the “Limit Ad Tracking,” “Opt out of Ads Personalization,” or equivalent setting from your mobile device will transmit a signal to us and any third parties that we use. When that signal is received by NutriLiv or third parties, it communicates your choice to not have Device IDs used for purposes of advertising or analytics. We honor the signal and require that our third party advertising and analytics partners do the same.

To the extent our App personalizes functionality for you, you can change these settings within the App, or reset to defaults by deleting and reinstalling the App.

Change Consent Settings for Communication Preferences

Consent for Email Communication: After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any commercial email we send. Please note that if you unsubscribe from “all emails” this means “all emails other than strictly necessary emails.” You will still receive email communications from us if they are strictly necessary to provide the Services or to confirm or validate a transaction, recover accounts, etc.

Mobile Push Notifications: You can manage the type of push notifications you receive from NutriLiv by modifying the settings within the App. For more information on how to update your push notification settings for our Services please visit here. You may also set your mobile device settings to not allow push notifications from us.

Transfers of Your Personal Data to Other Countries

The Personal Data NutriLiv processes, and all associated Services and systems, including registration, is housed on servers in the United States. If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States (the data protection and privacy laws in the United States may offer a lower level of protections than in your country/region).

By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the United States. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy.

Data Retention

We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your Personal Data upon your direction to delete your account. Information on how to make a deletion request can be found here or by contacting our support team.

If you have further questions about our data retention practices or would like to make a deletion request, please contact us through our support team.

Security

We implement technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

Links to Other Websites. Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites with that you interact with.

Children

We do not knowingly collect Personal Data online from individuals under 18. If you become aware that a child has provided us with Personal Data without parental consent, please contact us at Support@NutriLiv.app. If we become aware that an individual under 18 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel that individual’s account.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us at Contact@NutriLiv.app

You can also go to our location-specific disclosures to find a contact for the Data Protection Officer in your region, if applicable.

Location-Specific Disclosures

Residents of Argentina

You have the right to access your Personal Data, at intervals no shorter than six months entirely free of charge (unless there is proof of a legitimate interest in access in shorter periods, as established in Section 14, Sub-section 3 of Act No. 25,326).

We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint to the Agency of Access to Public Information, in its function of controlling agency responsible for enforcing Act No. 25,326.

Residents of Australia

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in Australia, you may request access to or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team or at the address listed above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

If you have any complaints regarding how we handle your Personal Data, please contact our support team or write to us at the address above with a detailed description of the complaint. Personalized Medicine responds to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Residents of Brazil

Legal Basis for Processing

We may rely on consent and/or another valid legal bases to process your Personal Data. Such legal bases may include: the legitimate interest of the controller or third parties; for compliance with a legal or regulatory obligation by the data controller; for the execution of a contract; for regular exercise of rights in court, administrative or arbitration proceedings.

How to Exercise Your Rights

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in Brazil, according to the LGPD, you have certain rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, at any time, please contact us through our support team or at the address listed above. Your request will be fulfilled at no cost, and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

You have the following rights:

Right to confirmation of the existence of the Processing of Personal Data: You have the right to ask us for confirmation on whether we are processing your Personal Data.
Right of access to your Personal Data: You have the right to request access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved) subject to commercial and industrial secrecy.
Right to correction of incomplete, inaccurate or out-of-date data: You have the right to have your Personal Data corrected, as permitted by law.
Right to anonymization, blocking or deletion of unnecessary or excessive data or data processed unlawfully. Anonymization refers to the use of reasonable and available technical means at the time of the processing, whereby the data loses the possibility of direct or indirect association with you.
Right to data portability: You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible, except for the data that has already been anonymized by us.
Right to erasure: You have the right to ask us to delete your Personal Data, as permitted by law. This right may be exercised when you withdraw your consent on which processing is based. Note that we may retain a limited amount of data for a period of time - including, in situations that the storage of the information is authorized by law and or required by law.
Right to information about public and private entities with which NutriLiv has shared data through communication, dissemination, international transfer, interconnection of personal data or shared processing of banks of personal data by them.
Right to information about the possibility of denying consent and the consequences of such denial;
Right to withdraw consent: You have the right to withdraw your consent to our processing of your Personal Data, as permitted by law, and where the basis for processing was based on your consent.
Right to object: When the legal basis for processing your data is anything other than consent, you can object to the processing when it is not in compliance with the law.
Right to review automated processing decisions: You have the right to review decisions taken solely on the bases of automated processing of personal data that affects your interests. This includes decisions intended to define your personal, professional, consumer or credit profile.

Changes to this Privacy Policy.

In order to enhance our Services it might be necessary to change this Privacy Policy from time to time. We therefore reserve the right to modify this Privacy Policy in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Privacy Policy.

How to Contact Us.

If you have any questions, comments, or concerns about how we handle your Personal Data, please contact at Contact@NutriLiv.app

Residents of China Mainland

How To Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, please contact at Contact@NutriLiv.app

Data Transfer

Principally, Personal Data collected in China Mainland will be stored within China Mainland. However, we provide Services through resources and servers located globally (including the United States), which means your Personal Data may be transferred to or accessed within another country/region outside of China Mainland. The data protection and privacy laws and principles in those countries/regions may not offer the same level of protection as those in China Mainland. Under those circumstances, NutriLiv will continue to protect your Personal Data in a manner consistent with what is expected under laws of China Mainland (e.g., we will obtain your consent to transfer your Personal Data, or de-identify the Personal Data before transfer).

Withholding Information

You may choose not to provide NutriLiv with your Personal Data. However, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services.

Residents of Colombia

How to Exercise Your Rights

NutriLiv takes steps to keep your Personal Data accurate and up to date. You have certain rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, please contact us through our support team or at the address listed below. We will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Right to access your Personal Data: You have the right to access, free of charge, your Personal Data being processed by us.
Right to know, update, and rectify your Personal Data: You have the right to correct your Personal Data, as permitted by law.
Right to request proof of your consent: You have the right to request proof of the consent granted to us for the processing of your Personal Data, where consent was required to process the information.
Right to withdraw your consent or to request the suppression of your Personal Data: You have the right to withdraw your consent or request that we suppress your Personal Data, as permitted by law.
Right to file complaints: You have the right to file complaints before the Superintendence of Industry and Trade for any kind of infringement to privacy laws.

Additional Use of Personal Data

Additional use of your Personal Data that is not described in this Privacy Policy will only take place as required by statute or when we have obtained your prior, explicit and informed consent.

How to Contact Us or Our Privacy Office

If you have any questions, comments, or concerns about how we handle your Personal Data, please contact at Contact@NutriLiv.app

Residents of the European Economic Area and the United Kingdom

If You Elect Not to Provide Personal Data

You may choose not to provide NutriLiv with your Personal Data. However, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services.

How to Exercise Your Rights

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in the European Economic Area, you have certain rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, please contact us at Contact@NutriLiv.app

Subject to applicable law and in exceptional circumstances only, we may charge for this service and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

You have the following rights:

Right of access to your Personal Data (Art. 15 GDPR): You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved).
Right to correction (Art. 16 GDPR): You have the right to have your Personal Data corrected if it is inaccurate and to have incomplete Personal Data about you completed, as permitted by law.
Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Data, as permitted by law. This right may be exercised among other things: (i) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR and where there is no other legal ground for processing; (iii) when you object to processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Art. 21 (2) GDPR; or (iv) when your Personal Data has been unlawfully processed.
Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances, including: (i) when the accuracy of your Personal Data is contested; (ii) when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead; or (iii) when you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of NutriLiv override your grounds.
Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible and as permitted by law.
Right to object (art.21 GDPR): You have the right to object to our processing of your Personal Data, as permitted by law. This right is limited to processing based on Art. 6 (1) (e) or (f) GDPR, and includes profiling based on those provisions. After which, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Furthermore, you have the right to object at any time to processing of Personal Data for direct marketing purposes.

How we may disclose your Personal Data

The GDPR and national laws of European Union member states implementing the GDPR permit the sharing of Personal Data relating to users who are residents of the European Economic Area with third parties only under certain circumstances. If you reside in the European Economic Area, we will only share your Personal Data as described in our Privacy Policy under the heading “How We Disclose Personal Data” if we are permitted to do so under applicable European and national data protection laws and regulations.

Health Data

Some Wellness Data that we collect may be considered personal health data under the GDPR as interpreted by the European data protection supervisory authorities if recorded over a longer period of time. We process this type of data to provide you with additional information that you can incorporate into your evaluation of your progress toward your wellness objectives; it should not, however, be considered professional medical advice and is not intended to be used for diagnostic purposes.

Transfers of Your Personal Data to Other Countries

The Personal Data NutriLiv processes, and all associated Services and systems, including registration, are housed on servers in the United States. If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States (the data protection and privacy laws in the United States may offer a lower level of protections than in your country/region).

In order to use our Services, we may require you to agree to the transfer, storage, and/or processing of your Personal Data in the United States. In other situations where Personal Data is transferred outside of the European Economic Area (the EEA) or the United Kingdom, NutriLiv leverages other mechanisms for international data transfer including the European Commission-approved standard contractual clauses and consent. You have the right to request a copy of the applicable measure or further information by contacting us at Contact@NutriLiv.app.

Marketing Communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. You may revoke your consent at any time (this will not affect the processing of your Personal Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do so at any time as outlined in the change consent settings for communication preferences section.

Legal Basis for Processing Under the GDPR

In this section we provide information on the legal basis for our processing of your Personal Data as required by Art. 13 and 14 of the GDPR:

When you register for an account or interact with our Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.
When you input Wellness Data within our Services: For sensitive data (including health data and biometric data) as defined in the GDPR, we process such data on the basis of your prior consent, Art. 9(2)(a) GDPR.
When you use or interact with a wearable or other connected device.

For sensitive data (including health data and biometric data) as defined in the GDPR, we process such data on the basis of your prior consent, Art. 9(2)(a) GDPR.
For non-sensitive Personal Data which we need in order to perform the Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.
With regard to other non-sensitive Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance our Services.

For sensitive data (including health data and biometric data) as defined in the GDPR, we process such data on the basis of your prior consent, Art. 9(2)(a) GDPR.
For non-sensitive Personal Data which we need in order to perform the Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.
With regard to other non-sensitive Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance our Services.

When you communicate with us or sign up for promotional materials, we process your Personal Data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with our promotional messages. Where we are required under applicable local law to obtain your consent for sending you marketing information, the legal basis is your consent, Art. 6(1)(a) GDPR.
When you participate in special activities, offers, or programs.

For sensitive data (health data) (including health data or biometric data) as defined in the GDPR, we process such data on the basis of your prior consent, Art. 9(2)(a) GDPR.
For non-sensitive Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with our promotional messages or to allow you to participate in our special activities, offers or programs or obtain prior consent, Art. 6 (1) (a) GDPR, if required by applicable law.

When you engage with our online communities or advertising and we actively collect your Personal Data in this context, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with our promotional messages.
When you access third party products and services and we obtain Personal Data about you from such third party sources:

For Personal Data that we need in order to perform the Services (e.g., if you pay for third party products through our Services), such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.
With regard to other Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance your experience and to improve our Services.

When you connect with us through social media:

Where we collect your consent in such case, for instance for marketing purposes, we process your Personal Data on the basis of your prior consent, Art. 6 (1) (a) GDPR.
Where we do not collect your consent in such case, we process your Personal Data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is providing you with better Services and to enable you to use the full range of our Services (Art. 6 (1) (f) GDPR).

When we collect data from third parties or publicly-available sources:

For Personal Data which we need in order to perform the Services (e.g., for email verification purposes), such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.
With regard to other Personal Data, we process your Personal Data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is providing you with better Services and to enable you to use our Services more efficiently.

When we leverage and/or collect cookies, device IDs, data from the environment, and other tracking technologies, we process your Personal Data on the basis of your consent, Art. 6 (1) (a) GDPR, and based on our legitimate interest, Art. 6 (1) (f) GDPR, to the extent permitted by applicable law.
When we use coarse location and data from sensors, we process such data for strictly necessary purposes in order to perform our Services, Art. 6 (1) (b) GDPR); and for our legitimate interest in marketing and improving our Services, Art. 6 (1) (f) GDPR).
When we aggregate or centralize data, such processing is either necessary for the performance of our Services, Art. 6 (1) (b) GDPR, or we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with better or customized Services and marketing.
When you sign up for our Services that consist of social sharing and communication with others (including linking you to friends across platforms):

Where we collect your consent in such case, we process your Personal Data on the basis of your prior consent, Art. 6 (1) (a) GDPR.
Where we do not collect your consent in such case, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

When you share content or achievements, or invite friends to use the Services:

Where we collect your consent in such case, we process your Personal Data on the basis of your prior consent, Art. 6 (1) (a) GDPR.
Where we do not collect your consent in such case, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

When we provide you geographically relevant Services, offers, or advertising:

Where we collect your consent in such case, we process your Personal Data on the basis of your prior consent, Art. 6 (1) (a) GDPR.
Where we do not collect your consent in such case, for such Personal Data that we need in order to perform the Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.
Where we do not collect your consent in such case and where we do not need such data in order to perform the Services, we process such data for our legitimate interest in offering you marketing and improving our Services, Art. 6 (1) (f) GDPR).

When you ask us to customize our Services:

Where we collect your consent in such case, we process your Personal Data on the basis of your prior consent, Art. 6 (1) (a) GDPR.
Where we do not collect your consent in such case, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

When we disclose Personal Data to our affiliates and partners, and to our service providers and vendors:

Where we collect your consent in such case, we process your Personal Data on the basis of your prior consent, Art. 6 (1) (a) GDPR.
Where we do not collect your consent in such case, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR, or we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with better Services and marketing.

When we process or share Personal Data in the event of an actual or contemplated sale, we process such data for our legitimate interest in offering, maintaining, providing, and improving our Services, Art. 6 (1) (f) GDPR).
When we conduct analytics, we process your Personal Data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance your experience and to develop and improve our Services.
When we investigate suspected illegal or wrongful activity, we process your Personal Data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to ensure compliance with legal requirements and law enforcement requests and for public safety purposes.

Right to Lodge a Complaint Before the Data Protection Authority

We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Data relating to you infringes applicable data protection laws.

Changes to this Privacy Policy

How to Contact Us or Our Privacy Office

NutriLiv, LLC is the data controller responsible for the processing of your Personal Data in connection with the Services. In case of questions about the processing of your Personal Data please contact us at Contact@NutriLiv.app

Residents of Hong Kong, SAR of China

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in Hong Kong, you may request access to or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team or at the address listed above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.
Your Consent for Use or Sharing of Personal Data for Marketing Purposes. You may choose not to provide NutriLiv with your Personal Data. However, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services. NutriLiv may use your Personal Data to communicate with you about NutriLiv Services you have purchased or used and to notify you of other products, Promotions and services we think may be of interest to you. We may also share Personal Data with our Ad Partners, business partners, vendors and suppliers who are providing you with products and services for their marketing purposes. You may provide your consent through the methods described in the next section.
How to Indicate Your Consent and Opt-Out. You may indicate your consent in a number of ways, including: (i) ticking a box to indicate your consent when providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or ticking a box to indicate your consent when registering with us or creating an account with us. You may opt-out from receiving marketing communications at any time, free of charge, through the methods described here.

Residents of Indonesia, Malaysia, Philippines, Thailand and Singapore

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in Indonesia, Malaysia, Philippines, Thailand or Singapore, you may request access to, and modification, opposition, and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Residents of Japan

Operator of Japan Websites

NutriLiv operates the Service, and collects, uses and shares your Personal Data as outlined in this Privacy Policy.

How NutriLiv Uses Personal Data

NutriLiv may use your Personal Data to communicate with you about the Services you have purchased or used and to notify you of other products, promotions and Services we think may be of interest to you.

NutriLiv will use the Personal Data you provide at registration for the following purposes:

Communicating with you about the use of the Services.
Communicating with you about activities related to the Services.
Delivering information (including advertisements) on products, services.
Providing you with updates on new uses of your Personal Data.
Providing registration support.
Providing e-mail support.
Creating statistical and analytic information.
Other inevitably necessary communications to you.
Leveraging and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies.
Providing you geographically relevant Services, offers, or advertising.
Complying with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes.

We may also share Personal Data with our Ad Partners, business partners, vendors and suppliers. The sharing of Personal Data to these organizations may mean your Personal Data is transferred to third parties located outside of Japan.

You may provide your consent through the methods described in the next section.

Consent for Use and/or Sharing of Personal Data

If you reside in Japan, by using the Services you consent to the collection, use and transfer of your Personal Data with NutriLiv as outlined in this Privacy Policy. Further, Personal Data collected will be shared as outlined in this Privacy Policy.

You may choose not to provide NutriLiv with your Personal Data. However, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services.

How to indicate your consent and opt-out

You may indicate your consent in a number of ways, including: (i) ticking a box to indicate your consent when providing NutriLiv with your Personal Data through the Services or a form (including enrolling in Promotions); (ii) or ticking a box to indicate your consent when registering or creating an account with NutriLiv. You may opt-out from receiving marketing communications at any time, free of charge, through the methods described here.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us at Contact@NutriLiv.app

Residents of Mexico

By using the Services, you consent to the collection, use and transfer of your Personal Data (including sensitive personal data pursuant to Mexican law) for processing in the United States as described in this policy.

Access Requests

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in Mexico, you may request access to, modification, cancelation or opposition of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team or at the address listed above. We may charge for this access service pursuant to applicable law and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Residents of New Zealand

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in New Zealand, you may request access to or correction of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team or at the address listed above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Residents of South Korea

NutriLiv Personal Data Items Collected

Mandatory: Email Address, Account Password, Billing Address, Gender, Date of Birth, postal code, IP address, browser history information, and cookies.

Optional: Email Address, Billing Address, Gender, Date of Birth, postal code, order history, phone number, IP address, browser history information, and cookies. Login and interaction information from social media and online communities.

Access Requests

NutriLiv takes steps to keep your Personal Data accurate and up to date. If you reside in South Korea, you may request access to, and modification, opposition and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team or at the address listed below. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Data Retention and Destruction

Under applicable Korean law, your Personal Data must be retained for the following periods:

Records regarding contracts or the cancellation of contracts, and records on payment and provision of goods:

Reason of retention: Act on Consumer Protection in Electronic Commerce Transactions, etc.
Retention period: five years

Records on customer complaints or dispute resolution:

Reason of retention: Act on Consumer Protection in Electronic Commerce Transactions, etc.
Retention period: three years

Communications confirmation data

Reason of retention: Communications Privacy Protection Act
Retention period: three months

Records on electronic financial transactions:

Reason of retention: Electronic Financial Transaction Act
Retention period: five years

Method and Procedure for the Destruction of Personal Data

NutriLiv retains your Personal Data (i) for as long as you maintain an account or as needed to provide you the Services and/or (ii) as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Personal Data is destroyed when it is no longer necessary for these purposes. The specific destruction process and method are as follows: (i) Personal Data printed on the paper is shredded, burned, pulped, pulverized, or incinerated; and (ii) Personal Data stored in electronic form is deleted using technology designed to prevent the recovery of the Personal Data.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us at Contact@NutriLiv.app

Residents of Turkey

By using the Services, you consent to the collection, use and transfer of your Personal Data with NutriLiv as outlined in this Privacy Policy. Further, Personal Data collected will be shared as outlined in this Privacy Policy.

Information Security. The Personal Data shared with NutriLiv will be protected using technical and organizational measures designed to protect your information against unauthorized access, theft, and loss as required by article 12 of the Law on Protection of Personal Data no. 6698.
Personal Data Accuracy. NutriLiv takes steps to keep your Personal Data accurate and up to date. You are responsible for the accuracy of the information you have provided to NutriLiv, and you understand that doing so is important in terms of exercising your personal data rights under the Law on Protection of Personal Data no. 6698 and other applicable legislation. To update your Personal Data, please contact us through our support team.
Access Requests. If you reside in Turkey, you may request access to, and modification, opposition and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.
Data Retention and Destruction. When you delete your account and/or when Personal Data is no longer needed to provide the Services or to comply with our legal obligations, resolve disputes, and enforce our agreements and/or the retention period under applicable law has expired, your Personal Data may be anonymized and continued to be used in that form.

Residents of the United Arab Emirates

If you reside in the United Arab Emirates, your use of the Services signifies your consent to the following:

You affirmatively waive your material privacy rights under applicable laws;
NutriLiv may disclose any information you provide us, including information you may consider private; and
NutriLiv is not liable for any publication of information you provide us, including information you may consider private.

Please do not use the Services if you disagree with any part of this Privacy Policy.

Residents of the United States

We don’t sell Personal Data as defined by Nevada law.

Residents of California

If you are a resident of California, you have certain rights to the Personal Data that we have collected about you. Under California law, the exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., maintaining confidentially when legally required ). We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. To prevent unauthorized access to your Personal Data, we take steps to verify an individual’s right to the data - including requiring users to reach out to us directly from a verified email address, pass a challenge response, and/or confirm information associated with the account. Following verification of your identity, we will notify you if we are unable to fulfill your request and outline the reasons we are unable to honor your request at this time.

Your California Privacy Rights

You have the following rights:

Right of Access to Your Personal Data: You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data, as permitted by law. This may include what Personal Data we collect, use, or disclose about you.
Right to Deletion: You have the right to ask us to delete your Personal Data, as permitted by law.
Right to Opt-out of “Sale” and Certain Sharing Practices: You have the right to opt-out of certain data sharing practices with third parties who may use your Personal Data solely for their own purposes. Your right to opt-out is limited to information we “sell” to these third parties. “Sell” in this case does not mean providing data in exchange for money – we don’t do that. “Sell” instead means the disclosure of data, including technical device data that does not identify you directly, when a third party might use that data for its own purposes, such as for personalized advertising. We do not have actual knowledge that we sell personal information of minors under 16 years of age.
Right to Non-Discrimination: We will not discriminate against you, in terms of price or services that we offer, if you submit one of the rights requests listed above.

How to Exercise Your Rights

Exercise your rights (other than opt-out of “sale”): To exercise your rights to your Personal Data, please contact us at Contact@NutriLiv.app

Exercise your opt-out of “sale” rights: For instructions on how to exercise your rights, please visit our “do not sell my personal information” page.

Additional California Rights

California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party’s direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

Under Section 1798.83, we currently do not share any Personal Data with third parties for their direct marketing purposes. If we do decide to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to Contact@NutriLiv.app

It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing.