Effective Date: March 13 2019
Notice Version: 1.0
Data Controller Contact Information:
Reinagel Communications, LLC
732 Deepdene Rd, #16206
Baltimore, MD 21210
This document governs the privacy notice of our mobile app Nutrition GPA. Our privacy notice tells you what personal data and non personal data we may collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere.
‘NON PERSONAL DATA’ (NPD) is information that is in no way personally identifiable.
‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data. (GDPR) means General Data Protection Regulation.
Table of Contents
- Your Rights
- Information We Collect and How We Collect It
- How Your Information Is Used and Shared
- Retaining and Destroying Your PD
- Updating Your PD
- Revoking Your Consent for Using Your PD
- Protecting the Privacy Rights of Third Parties
- Do Not Track Settings
- Links to Other Websites
- Protecting Children’s Privacy
- Our Email Policy
- Our Security Policy
- Use of Your Credit Card
- Transferring PD from the European Union
- Changes to Our Privacy Notice
When using our services and submitting PD to us, you may have certain rights under the GDPR if you reside or are in any of the countries of the European Union. Depending on the legal basis for processing your PD you may have some or all of the following rights:
- The Right to Be Informed – You have the right to be informed about the PD that we collect from you and how we process them.
- The Right of Access – You have the right to get confirmation that your PD are being processed and you have the ability to access your PD.
- The Right to Rectification – You have the right to have your PD corrected if they are inaccurate or incomplete.
- The Right to Erasure (Right to Be Forgotten) – You have the right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing them.
- The Right to Restrict Processing – You have the right to ‘block’ or restrict the processing of your PD. When your PD are restricted, we are permitted to store your data, but not to process them further.
- The Right to Data Portability – You have the right to request your PD that you provided to us and use them for your own purposes. We will provide your data to you within 30 days of your request. Contact us using the information at the top of this privacy notice to request your PD.
- The Right to Object – You have the right to object to us processing your PD for the following reasons:
- Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
- Direct marketing (including profiling)
- Processing for purposes of scientific/historical research and statistics
- Rights in relation to automated decision-making and profiling.
- Automated Individual Decision-Making and Profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects regarding you or similarly significantly affects you.
- Filing a Complaint with Authorities – You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
Information We Collect and How We Collect It
Generally, you control the amount and type of information that you provide to us when using our mobile app.
Our Legal Basis for Collecting and Processing PD
Our legal basis for collecting and processing your PD when you buy our products or services is based on and the necessity for the performance of a contract or to take steps to enter into a contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter, download free information, access free audios, videos, and webinars through our mobile app, including information you enter using any of our opt-in forms is based on consent.
We automatically receive information from your web browser or mobile device. This information may also include the IP address of your device/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, and data about your browsing activity when using our mobile app. We use all this information to analyze trends among our users to help improve our mobile app.
When Using Our Mobile App
When you use our mobile app and agree to accept cookies, some of these cookies may contain your PD.
- Performance Cookies – These cookies collect information about the use of the mobile app, such as pages visited, traffic sources, users’ interests, content management, and other mobile app measurements.
- Functional Cookies – These cookies enable the mobile app to remember users’ choices, such as their language, usernames, and other choices while using the mobile app. They can also be used to deliver services, such as letting a user create a blog post, listen to audios, or watch videos.
- Media Cookies – These cookies can be used to improve a mobile app’s performance and provide special features and content. They can be placed by us or third parties who provide services to us.
- Advertising or Targeting Cookies – These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other mobile apps and websites that are related to your interests. You will see less advertising if you disable these cookies.
- Session Cookies – These cookies allow mobile apps to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they use a mobile app. Session cookie also permit users to be recognized as they navigate a mobile app so that any item or page changes they make are remembered. Session cookies expire after a browser session; they are not stored long term.
- Persistent Cookies – These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a mobile app or across different mobile apps or websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences when using a mobile app or to target advertising to them.
- identifying the areas of our mobile that you have visited
- personalizing content that you see
- our mobile app analytics
- remarketing our products or services to you
- remembering your preferences, settings, and login details
- targeted advertising and serving ads relevant to your interests
- affiliate marketing
- allowing you to post comments
- allowing you to share content with social networks.
We may also use a technology called web beacons to collect general information about your use of our mobile app and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers and users.
At User Registration
When you register as a user, we collect your name and email address.
When Buying Products or Services
If you buy products or services from us, we collect your first and last name, email address, physical address, credit card or other payment information, phone number, and other information listed.
Chat Software or Contact Forms
Our mobile app contains chat software or contact forms that enable visitors to communicate with us live online or offline by email. In some cases visitors can communicate with us without buying our products and services. When you use our chat software or contact forms, we may collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to give us. You should limit the information you give to us to one that is necessary to answer your questions.
Our mobile app uses Google Analytics to collect information about the use of our mobile app. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our mobile app, what pages they visit, and what other websites they have used before coming to our mobile app. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and mobile app. Google Analytics collects only the IP address assigned to you on the date you visit our mobile app, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our mobile app, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our mobile app.
- For more information on how Google collects and processes your data visit: https://www.google.com/policies/privacy/partners/
- You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout
What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you all our products and services.
How Your Information Is Used and Shared
We use the information we receive from you to:
- provide our products and services you have requested or purchased from us
- personalize and customize our content
- make improvements to our mobile app
- contact you with updates to our mobile app, products, and services
- resolve problems and disputes
- contact you with marketing and advertising that we believe may be of interest to you.
Communications and Emails
When we communicate with you about our mobile app, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our mobile app or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the contact information at the top of this privacy notice.
Sharing Information with Affiliates and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may give your PD to third-party service providers whom we hire to provide services to us. These third-party service providers may include but are not limited to payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
Text Messaging and Push Notifications
If you provide a mobile telephone number to us, you are giving your consent and authorize us or a third party to send you text messages and push notifications. You are not required to give us your consent for these text messages and push notifications. However, withholding your consent may interfere or prevent us from providing some or all of our services to you. You can stop receiving text messages and push notifications at any time.
Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or governmental enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing our mobile app to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Community Discussion Boards, Blogs, or Other Mechanisms
Our mobile app may offer the ability for users to communicate through online community discussion boards, blogs, or other mechanisms. We do not filter or monitor what is posted on such discussion mechanisms. If you choose to post on these discussion mechanisms, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD through such postings. Also, PD which you post on our mobile app for publication may be available worldwide by means of the Internet. We cannot prevent the use or misuse of such information by others.
Retaining and Destroying Your PD
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.
Updating Your PD
You can update your PD using services found on our mobile app. If no such services exist, you can contact us using the contact information found at the top of this privacy notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.
Revoking Your Consent for Using Your PD
You have the right to revoke your consent for us to use your PD at any time. Such opt-out will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, please contact us through the contact information at the top of this privacy notice.
Protecting the Privacy Rights of Third Parties
If any postings you make on our mobile app contain information about third parties, you agree to make sure that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.
Do Not Track Settings
Some web browsers have settings that enable you to request that our mobile app not track your movement within our mobile app. Our mobile app does not obey such settings when transmitted to and detected by our mobile app. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.
Links to Other Websites
Our mobile app may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.
Protecting Children’s Privacy
Even though our mobile app is not designed for use by anyone under the age of 18, we realize that a child under the age of 18 may attempt to access our mobile app. We do not knowingly collect PD from children under the age of 18. If you are a parent or guardian and believe that your child is using our mobile app, please contact us. Before we remove any information we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our mobile app, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.
Our Email Policy
You can always opt out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.
Our Security Policy
We have built our mobile app using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any login information and password you may have for our mobile app and not share it with anyone.
Use of Your Credit Card
You may have to provide a credit card to buy products and services from us. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
Transferring PD from the European Union
PD that we collect from you may be stored, processed, and transferred among any countries in which we operate. The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a European Union customer or user, with your consent your PD may be transferred to the United States or other countries outside the European Union when you request information from us. When you buy goods or services from us, we will use your PD for the performance of a contract or to take steps to enter into a contract. Wherever we transfer, process, or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our mobile app, services, or products you agree to the transfers of your PD described within this section.
Changes to Our Privacy Notice
We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our mobile app so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases your continued use of our mobile app, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.
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