“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
Transparency / Notice — Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with Nutroo.AI and the requirements of applicable law. Some of the ways that we may collect Personal Information include:
• You may provide Personal Information directly to us through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Collection and Use of Information
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.
Types of Personal Information We Collect
Nutroo.AI collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”).
Information You Provide Directly to Us
When you use the Services or engage in certain activities, such as registering for an Account, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Communications with Us
• We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Nutroo.AI newsletter or a program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
• From time to time, we may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/ or Services and in any manner consistent with the policies provided herein.
Posting on the Site
• Nutroo.AI may offer publicly accessible fun pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Nutroo.AI's fun pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Registration for Sweepstakes or Contests
• Occasionally, we may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.
Automatic Data Collection
• We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, Game Center ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information Submitted Via Services
You agree that Nutroo.AI is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Information from Other Sources
We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you create an Account using your login credentials from one of your SNS Accounts, we’ll be able to access and collect your name and other Personal Information that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered Personal Information because it cannot be used by itself to identify you. This supplemental information allows us to verify information that you have provided to Nutroo.AI and to enhance our ability to provide you with information about our business, products, and Services.
Information Collected Using Cookies and other Web Technologies
Cookies and Web Beacons to collect certain information.
• “Pixels”/“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
• We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related
• We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
In some cases we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
Social Media Platforms
Nutroo.AI Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
Third-Party Payment Processing
We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), Social Networking Sites (“SNS”) such as Facebook, and other third-party payment processers, including Stripe. The third party application may collect certain financial information from you to process a payment on behalf of Nutroo.AI, including your name, email address, address and other billing information.
Human Resources Data
Nutroo.AI collects Personal Information from current, prospective, and former employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
• Workflow management, including assigning, managing and administering projects
• Human Resources administration and communication
• Payroll and the provision of benefits
• Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs
• Job grading activities
• Performance and employee development management
• Organizational development and succession planning
• Benefits and personnel administration
• Absence management
• Helpdesk and IT support services
• Regulatory compliance
• Internal and/or external or governmental compliance investigations
• Internal or external audits
• Litigation evaluation, prosecution, and defense
• Diversity and inclusion initiatives
• Restructuring and relocation
• Emergency contacts and services
• Employee safety
• Compliance with statutory requirements
• Processing of Employee expenses and travel charges, and
• Acquisitions, divestitures, and integrations.
How We Use Your Information
We acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested
We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
• Generally manage Individual information and Accounts
• Respond to questions, comments, and other requests
• Provide access to certain areas, functionalities, and features of Nutroo.AI Services
• Contact you to answer requests for customer support or technical support
• Allow you to register for events
We may use Personal Information about you for administrative purposes, including to:
• Measure interest in Nutroo.AI Services
• Develop new products and Services
• Ensure internal quality control
• Verify Individual identity
• Communicate about Individual Accounts and activities on our Services and systems, and, in Nutroo.AI discretion, changes to any Nutroo.AI policy
• Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance
• Process payment for products or services purchased
• Process applications and transactions
• Prevent potentially prohibited or illegal activities
• Enforce our Terms
Marketing Nutroo.AI Products and Services
We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
• To tailor content, advertisements, and offers
• To notify you about offers, products, and services that may be of interest to you
• To provide Services to you and our sponsors
• For other purposes disclosed at the time that Individuals provide Personal Information, or
• Otherwise with your consent
Research and Development
We may use Personal Information to create nonidentifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Nutroo.AI may perform research (online and offline) via surveys. We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing
Services via Mobile Devices
Anonymous and Aggregated Information Use
We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Nutroo.AI Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Nutroo.AI and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues
Nutroo.AI Services may offer various tools and functionalities. For example, Nutroo.AI allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other third parties for any other purpose.
We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Information That We Share With Third Parties
We will not share any Personal Information that we have collected from or regarding you except as described below
Information Shared with Our Services Providers
We may engage third party service providers to work with us to administer and provide the Services. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Nutroo.AI has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
We may also share your Personal Information with our marketing service providers to help us better market our products and services to you. Our marketing service providers may use your Personal Information only for the purpose of helping us better market our products and services to you and are prohibited from transferring your Personal Information to others. If you don’t want Nutroo.AI to use your information for these purposes, you can opt out by contacting us at email@example.com.
Information Shared with Business Partners
We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Nutroo.AI. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Nutroo.AI provided them.
Information Shared with Other Systems, Such As HealthKit or Google Fit
• Nutroo.AI does not use or disclose to third parties user data or other information gained through the use of the HealthKit framework or Google Fit for advertising, other use- based data mining purposes or similar services, other than for purposes of improving health or for purposes of health or medical research.
• In the case of information gained through HealthKit or Google Fit such sharing will only be for purposes of enabling the third party to provide health and/or fitness services or for medical research.
• We do not sell any of your information, including information gained through HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.
• We do not use any of the information obtained through HealthKit or Google Fit for any purpose other than providing health and/or fitness services in connection with the Services.
Information Shared with Other Third Parties
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.
Information Disclosed in Connection with Business Transactions
Information that we collect from our users, including Personal Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials and/or private parties to enforce and comply with the law. We may access, preserve, and disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal process and comply with law enforcement or national security requests (including subpoenas, warrants or court orders); (ii) to protect your, our, or other’s property, rights and safety and the rights, property and safety of a third party or the public in general; (iii) to prevent or stop any activity we consider illegal, unethical or legally actionable activity; (iv) to respond to your requests; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Your Choices & Opt-Out
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Nutroo.AI processing of your Personal Information, you may withdraw that consent at any time and opt-out to further processing by contacting us at firstname.lastname@example.org. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/ or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
We may occasionally send you push notifications through our mobile applications with updates and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Human Resources Data
With regard to Personal Information that Nutroo.AI receives in connection with the employment relationship, we will use such Personal Information only for employmentrelated purposes as more fully described above. If Nutroo.AI intends to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to opt-out of such uses.
Modifying Your Information
You can access and modify the Personal Information associated with your Account through your Account settings or by contacting us at email@example.com. If you want us to delete your Personal Information and your Account, please contact us to firstname.lastname@example.org with your request. We’ll take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Responding to Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Our Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.
Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/ managing/opt_out.asp, or youronlinechoices.eu/ and aboutads.info/choices. You can also choose not to be included in Google Analytics here.
Rights of Access, Rectification, Erasure, and Restriction
Although Nutroo.AI makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
Links to Other Sites
Our Policy Toward Children
Our Services are not directed to children under 16 and we do not knowingly collect Personal Information from children under 16. If we learn that we have collected Personal Information of a child under 16 we will take steps to delete such information from our files as soon as possible. If you are under the age of 18, you must have your parent’s permission to access the Services.
California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Nutroo.AI does not share Personal Information with third parties for their own marketing purposes.
Effective as of: 21 March 2019