WHO WE ARE?
1.1 NATURALPIXEL S.R.L. is a Romanian legal entity based in Bucharest, street Pridvorului nr. 19, parter, Bloc 20, Sc. 1, Ap. 2., unique registration code 37372585 from de 11.04.2017, registered with the Trade Registry under no. J40/S0S3/2017, (“Company” or “we“). For the purposes of personal data protection law, we are the “data controller” or “data controller empowered representative“, as the case may be, with respect to personal data provided and processed through the app.nutritioapp.com web application (“Nutritio Application“).
1.2 The Company collects and processes the personal data of Professional Users as a personal data operator.
1.3 The Company collects and processes the personal data of Patient Users as authorized by the data controller relevant to each Patient User. Patient users as individuals are able to verify the identity of the data operator, as well as his contact details in the “My Coach” area of the Nutritio Application or through the nutritional plan submitted to Patient User via email.
Table of Contents
- What personal data do we collect and how do we get it?
- How do we get personal data about you?
- The purpose of processing your personal data
- The grounds for processing your personal data
- Disclosure of your personal data
- Transfer of personal data to third party countries
- How long do we keep your personal data?
- What level of security do we ensure for your personal data?
- Your rights
- What if you do not want to provide us with your personal information?
- Data Protection Officer
1. What personal data do we collect and where do we get it?
1.1 The personal data that the Company collects about you through the Nutritio Application differs depending on the type of user you register with.
1.2 When you register with the Nutritio Application as Patient User , we will collect as a Personal Data Operator (“General Personal Patient Data”), the following:
- basic data about you: your first name, last name, date of birth, age, sex, your profile picture;
- contact details: personal address, email address and phone number;
- information collected from your visits to our websites, including the type of browser and operating system you are using, the access times, the viewed pages, the URLs you clicked, the IP address, and the page you visited before coming on our websites;
1.3 After registering with the Nutritio Application in Patient User Mode, we may collect, following your express consent, the following personal data (“Patient Sensitive Data”):
- data about your health: information on the conditions you suffer such as chronic diseases;
- anthropometric data such as height, body mass index, weight, waistline circumference ;
- your food preferences, job;
- sports activities, constitution, ideal weight (kg or lbs), weekly training, duration of training;
- whether you are a smoker or not, to what extent you drink alcohol, special medical conditions such as pregnancy, pictures showing progress on weight loss.
1.3 In order to process the Patient Sensitive Data, it is necessary to obtain your express, specific, informed and free consent in accordance with the consent form provided through the Nutritio Application at the time of registering with the application or at the time of entering your personal data.
1.4 When registering on the Site as a Professional User, we will collect the following Personal Data (“Personal Data of Professionals”) as the data operator:
- basic data about you: name, first name, date of birth, age, sex, image;
- contact details: personal address, email address and phone number;
- data on education: the form of education you are following, as well as the estimated completion date of the studies.
2. How do we get personal data about you?
2.1 General Personal Patient Data is collected when you register on the Nutritio Application or by completing form made available via email provided by Your Nutrition Professional who appears under “My Coach “Within the Nutritio Application.
2.2 Sensitive Patient Data can be collected directly by your personal Professional and then entered by the Professional in the Nutritio Application or may be entered by you in the relevant sections of the Nutritio Application.
2.2. Personal Information of Professionals is collected when you register with the Nutritio Application.
3. The grounds for processing your personal data
3.1 The Company processes the General Personal Data of Patients in order to execute the contract that the Company has concluded with you as a result of accepting the Nutritio Terms and Conditions. In this way, your Professional who appears in the “My Coach” section can make available to you totally or partially the services of the contract concluded between you and your Nutritionist Professional.
3.2 The Company processes Sensitive Patient Data on your express, specific, informed and free consent in accordance with the consent form provided through the Nutritio Application at the time of registering with the application or the time of entering your personal data.
3.3 The Company processes the Personal Data of the Professionals in order to execute the contract that the Company has concluded with the Professional User or to take steps at the request of the Professional User before concluding a contract.
3.4 The Company processes the Personal Data of Professionals for legitimate business purposes such as: administering and improving our business, as well as minimizing any interruption of the services we offer. It also allows us to prepare more relevant and customized communications for you and provide you with an efficient and effective experience with our products and services.
4. The purpose of processing your personal data
4.1 The Patient Users’ Personal Data is used for the following purposes:
- your basic data and contact details are used by the Company to allow you to create your account in the Nutritio application, to contact and interact with you, to answer your questions and ask for feedback, for example, changes to our terms, conditions and policies, and to send you technical notices, updates, security alerts, and support and administrative messages;
- your contact details are used by your Professional, which personal data apears in the “My Coach” section of the application, to generate customized nutritional plans and recommendations;
- basic data about you and contact details are used by your Professional, whose data is in the Nutritio “My Coach” section, so that he can communicate with you real-time adjustments to your nutritional plans, keep your motivation for the period of the diet you are following, until you reach your set goals.
4.2 Sensitive Patient Data is used by your Professional, which personal data appears in the “My Coach” section of the application, to generate personalized nutritional plans and recommendations, for real-time adjustment to your nutritional plans, keep your motivation for the period of the diet you are following, until you reach your set goals.
4.3 Professional User Data is used by the Company to contact you and interact with you, to answer questions and ask for feedback, to send important notifications, such as changes to our terms, conditions and policies, and for sending you technical, administrative, updates, security alerts, up-grades to your current pricing plans or options the Company wishes to introduce to you if you do not complete the registration procedure.
4.4 Data about the education of Professional Users is used to establish the applicable pricing plan for using the Nutritio Application by a Professional User.
5. Disclosure of your personal data
We may disclose your personal data to the following trusted third parties: our agencies and suppliers, including those providing technical services such as data analysis, hosting and technical support; our professional consultants and our auditors; courts, regulators, public administrations and law enforcement authorities, local or foreign, and other third parties, in connection with sales, mergers, acquisitions or reorganization of all or some of our activities. A complete list of third parties to whom we disclose your personal data may be obtained free of charge through a written request sent to: email@example.com.
6. Transfer of personal data to third party countries
6.1 Your personal data may be transferred to countries outside the European Economic Area in the case of emails submitted via the Nutritio Application that uses a service provider located in the United States of America. In this case, before we actually transfer your personal data, we have ensured that there is an appropriate framework for personal data protection, in particular the certification of our supplier with EU-US Privacy Shield.
7. How long do we keep your personal data?
7.1 As a general rule, we retain your personal data for as long as it is necessary (a) to comply with the law, (b) in the context of a court action or an investigation into which the Company is involved, or (c) to provide you with information or access to our products and services.
7.2 Upon expiration of the duration mentioned in Article 7.1 above, we will keep Patient Personal Data and Personal Data of Professionals for a period of two (2) years.
8. What level of security do we ensure for your personal data?
8.1 The Company uses a wide range of security measures and technologies to protect your personal data from unauthorized access, use, disclosure, modification or destruction in accordance with applicable privacy and data protection laws.
8.2 For example, when we divulge your personal information with external providers as outlined in Article 5 above, we enter into a written agreement that forces suppliers to keep your information confidential and to put in place appropriate security measures to keep your information safe.
9. Your rights regarding the processing of personal data
9.1 You have right to:
- request from the Company information about processing your personal data, including receiving a copy of your personal data;
- ask for the modification and / or deletion of your personal data;
- request that you restrict the processing of your personal data or object to the processing;
- to withdraw your consent to the processing of Sensitive Patient Data;
- request the receipt or transmission to another organization, in an electronically processable form, of the personal data you have provided to the Company; and
- submit a complaint to the National Supervisory Authority for Personal Data Processing located in B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucuresti, Romania, e-mail address: firstname.lastname@example.org, if you believe your data protection rights are violated.
9.2 If you wish to exercise your rights, please let us know by contacting us at email@example.com.
10. What if you do not want to provide us with your personal information?
10.1 If you choose not to provide us with your personal data, if you oppose the processing of your personal data by us or if you choose to withdraw your prior consent for any processing, we will comply with this choice in accordance with its legal obligations. However, this means that we can not take the necessary actions to achieve the processing goals described above in the “Purpose of Your Personal Data Processing” section or that you will not be able to use the services and products offered by the Nutritio Application.
10.2 The Company may be required or may have the right to retain your data, to comply with its statutory or regulatory obligations and to protect or exercise its own legal rights and interests.
11. Data Protection Officer
If you have any questions or requests regarding the processing of your personal data or if you need additional information, please contact the Company Data Protection Officer at: firstname.lastname@example.org.