PRIVACY
POLICY
PRIVACY
POLICY
Welcome to Nuchido Inc.'s privacy policy.
Nuchido Inc. (collectively referred to as "we", "us" or "our" in this privacy policy) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
Purpose of this privacy policy
This privacy policy aims to give you information on how Nuchido Inc. collects and processes your personal and special category data (known as "sensitive data") through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children. We will use commercially reasonable efforts to delete information associated with a minor as soon as practicable if we learn that a minor has submitted information to us.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data and sensitive data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
Controller
For purposes of applicable data protection law, Nuchido Inc. is the controller, in respect of your personal data collected and used through your use of this site. This is because we dictate the purpose for which your personal data is used and how we use your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights , please contact the data privacy manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Nuchido Inc.
Email address: privacy@nuchido.com
Postal address: 1209 Orange Street, Wilmington, New Castle, Delaware, 19801
Telephone number: 1-314-260-7874
Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 1 July 2019. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Please note that we may not be able to correct or update your personal data previously provided to us by third parties.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
-Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
-Contact Data includes billing address, delivery address, email address and telephone numbers.
-Financial Data includes bank account and payment card details.
-Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
-Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
-Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
-Usage Data includes information about how you use our website, products and services.
-Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
-Health Data includes personal medical history (which may include NAD, telomeres, inflammatory, biomarkers of ageing), activity levels (such as sleep patterns) and details of your weight, height, body mass index (BMI), genome data, proteome data, dexascan data and ultraviolet imagery, all of which are sensitive data. Full details of any adverse event reactions or complaints made by customers, including copies of correspondence.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We will only collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) with your express consent. We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
-Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
-apply for our products or services;
-using our health app;
-create an account on our website;
-subscribe to our service or publications;
-request marketing to be sent to you;
-enter a competition, promotion or survey; or
-give us some feedback.
-Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
-Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
-Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks; and
(c) search information providers.
-Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
-Health Data from you, your doctor and third party providers of testing services (including testing services carried out in respect of samples provided by you).
-Identity and Contact Data from data brokers or aggregators.
-Identity and Contact Data from publicly availably sources such as social media platforms.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
-Where we need to perform the contract we are about to enter into or have entered into with you.
-To more accurately tailor the products and services we supply to you.
-Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
-Where we need to comply with a legal or regulatory obligation.
-Where we need to comply with best practice as a food business operator to ensure the quality and safety of our products.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sensitive data and sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us .
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new customer |
(a) Identity (b) Contact (c) Health |
Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Health |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To tailor products and services to you. To monitor and review adverse event reactions and customer complaints to ensure the quality and safety of our products. |
(a) Identity (b) Transaction (c) Health |
(a) Performance of a contract with you (b) Necessary to comply with obligations to meet legal, regulatory and best practice requirements |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To research, develop and improve our products and services. This will include the collection of data for participants in clinical trials. |
(a) Identity (b) Health (c) Profile (d) Usage (e) Technical
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Necessary for our legitimate interests (to improve the products and services offered to our customers) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
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Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre you can view and make certain decisions about your personal data use.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes. If you are a California resident, see “Your Rights” section below for more information on your rights related to this sharing.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us .
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data or sensitive with the parties set out below for the purposes set out in the table in section 4 above.
-External Third Parties as set out in the Glossary .
-Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties listed above to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share your personal data with external agencies and organizations (including law enforcement and the relevant local authority) for the purpose of complying with applicable legal and regulatory obligations.
We may transfer your personal data outside the United States of America (USA).
-Whenever we transfer your personal data out of the USA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
-We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant legal and regulatory authorities in the USA.
-Where we use certain service providers, we may use specific contracts approved by the relevant legal and regulatory authorities in the USA which give personal data the same protection it has in the USA.
-Where we use providers based in the European Economic Area, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the USA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website and any transmission is at your own risk. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code (the “Shine the Light Law”), residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information, if any, the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, write to Nuchido Inc., 1209 Orange Street, Wilmington, New Castle, Delaware, 19801, Attention: CA Privacy Requests, or email privacy@nuchido.com with the subject line “CA Privacy Requests”. We will endeavor to respond to such requests within a reasonable time by providing a report that includes the information required by applicable law. Please be advised that we are not required to respond to requests from any individual resident under the Shine the Light Law more frequently than once per calendar year. If any other state enacts a similar law as the California law, then this provision will also apply to such state.
Do-not-track disclosure; third-party tracking
Certain mechanisms may allow you to send web browser signals, known as “Do Not Track” (“DNT”) signals, indicating your choice to disable tracking on the Site. We do not respond to browser do not track signals at this time. We may not be aware of or able to honor and respond to every such mechanism. More information about “do not track” is available at http://www.allaboutdnt.org concerning such information.
Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting the Site. That said, we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.
Your rights if you are located in the EU/EEA/UK
If you are located in the EU/EEA/UK, then under certain circumstances, you have rights under data protection laws in relation to your personal data.
-Request access to your personal data.
-Request correction of your personal data.
-Request erasure of your personal data.
-Object to processing of your personal data.
-Request restriction of processing your personal data.
-Request transfer of your personal data.
-Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at privacy@nuchido.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please contact us at privacy@nuchido.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
Service providers who provide testing, IT and system administration services.Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.Third parties where you have opted-in to our sharing your information for third-party marketing.Third party suppliers of our products and services and third party fulfilment groups who deliver our products.Government bodies, agencies, regulators and other authorities acting as processors or joint controllers who by law require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.