Privacy Policy for Customers, Suppliers, Business Persons, Website and Application Visitors, Employees and Applicants

1.  Overview

Welcome to the Nutrino website and/or application.  Protecting the security and privacy of your personal data is important to us. For this reason, Nutrino processes personal data in compliance with applicable laws on data protection and data security.

BY USING THIS WEBSITE OR APPLICATION, YOU ARE AGREEING TO THE PRACTICES AS STATED IN THIS PRIVACY POLICY (AS UPDATED OR AMENDED FROM TIME TO TIME) AND OUR TERMS OF USE. IF YOU DO NOT AGREE TO THE TERMS AS STATED ABOVE, PLEASE STOP USING THIS WEBSITE OR APPLICATION IMMEDIATELY.”

Who we are

This Website or Application is operated by NUTRINO.  As used in this Privacy Policy, the terms “NUTRINO”, “we”, “us” and “our” refer to NUTRINO HEALTH Ltd. and all entities it controls, is controlled by or is under common control with, including parents, affiliates, and subsidiaries, which under this Privacy Notice may act as a Controller of your personal information, namely deciding how and why your personal information is being processed.

2.  Scope

This Privacy Policy applies to all the personal information we collect about you when you interact with us through our website, mobile applications or other forms of communication.

These interactions may occur when you:

• visit our websites or web shops;
• download and use our mobile app;
• use or purchase our products or services;
• subscribe to our newsletters, participate in our online communities, sweepstakes and other competitions;
• contact our customer support;
• request information specific to your interests;
• offer us products or services;
• interact with us as an employee or applicant.

3.  Information we may collect about you.

We may process several types of personal information about you depending on your capacity as e.g. a consumer, costumer or business partner, and the ways you interact with us.

If you choose not to provide us with your personal information, please understand that we might not be able to provide you with the requested product, service, solution or respond to some of your requests.

3.1. Information you provide to us

• Contact information (name, address, email, telephone etc.);
• Account login information: usernames, passwords;
• General Business information such as address, contact person, invoicing and other payment information, delivery information.;
• Reviews, feedback, comments;
• Audiovisual information, such as pictures or video;
• Recruitment data: CV, application forms, letters of recommendation, languages, qualification, certifications, trainings, and other professional licenses, etc.;
• Talent management information, such as employment and education history, other details included in the CVs; professional qualifications and experience, performance and development programs and reviews and career development plans, etc.
• Information regarding your health, health goals, body measurements, allergies, activity level, taste in food, food intake, exercise, sleep, and other information that you voluntarily provide us.
• Information which part of the voluntary health tests as provided on the application, including answering questions about your age, date of birth, gender, ethnicity, dietary and health history, family health history, exercise history and body measurements.
• Information that you provide us by means of our App, such as, without limitation, feedback and responses to recommended dishes, menus, recipes, packaged foods and restaurant meals, and when you make purchases of foods and/or reservations at restaurants.

3.2. Information we automatically collect about you

• Traffic information such as time and/or duration of your interaction with us
• IP address, MAC address of the devices with which you interact with us.
• Location information (meaning your actual location concluded by the information mentioned above);
• Information related to your interests (products or services that you are visiting on our website platforms)
• Cookies preferences

4.  Why we collect your personal information

Depending on who you are, we may collect personal information for different purposes.

• Services: Your information may be required in order to provide you with the requested goods or services or to fulfil other purposes which you have requested from us, as well as further develop, customize and improve our services.
• Support: Providing you with customer support, responding to your questions or requests, to maintain account security and for other website or app maintenance reasons.
• Marketing: To facilitate direct marketing, promotions, newsletters and website analysis.
• Legal: Performance and execution of contracts, due diligence and compliance with our legal obligations.

5.  Why do we need your information?

Under Article 6(1) of the GDPR, we are only permitted to process your data if there is a legal basis to do so.  A legal basis for processing your data will arise when one or more of the following conditions apply:

• You have provided your consent to the processing, when required according to applicable data protection laws;
• The processing is necessary for the facilitation of the performance of our contractual obligations arising from your employment contract;
• In compliance with applicable legal applicable obligations;
• The processing is necessary for the purposes of the legitimate interests pursued by Nutrino or by a third party, except where your interests or fundamental rights and freedoms which require protection of personal data override such interests;
• The processing is necessary for the protection of vital interests of any natural person;

6.  How long we keep your information

We retain your personal information as long as it is necessary to fulfil the specific purposes, as explained under the section “Why we collect your personal information”. In specific cases, a longer retention of your personal information might be required according to legal obligations.

In all other cases, we delete your personal information once the purpose of processing your information has been fulfilled.

7.   Third Party and Online Links to Other Sites

This Privacy Notice applies only to Nutrino and its products or services and not to other websites or applications operated by third parties.

We do not integrate any social media plugins directly into our website. Therefore, your data will only be transferred to the extent that we additionally inform you on our Cookie Policy. Our website may contain links to social media or other third-party sites or applications. Nutrino is not responsible for the privacy practices of such other websites or applications.  We recommend that you review the privacy policy of any third-party sites or links you may choose to visit for further information.

Further Third-Party Information

You may connect our Services to Third-Party Applications or Devices. If you use the Services by logging on through a social media account and/or a Third-Party Application or by connecting to a Third-Party Application or third-party device we may also receive personal information about you which is provided by such social network, Third-Party Application, and/or Third-Party Devices including information regarding health, lifestyle and exercise activities.

Please check the policies of such social network, Third-Party Application and/or third-party devices in order to understand what information we receive.

If we will enable direct payment through our Services, we will collect and store billing and credit card information.

We also use third-party service providers and business partners in the health, medical and/or fitness field to offer you additional products and services.  If you choose to use these products or services, we may share your personal data with them to the extent necessary for such providers to offer you their products or perform their services. Accordingly, we encourage you to review any third-party’s privacy policy for further information

8.  Cookies

When you visit our websites or in our digital platforms in general, cookies might be stored on your devices within the web browser. Cookies are small text files that can store information for a certain period and identify your device. We use cookies in order to provide you the possibility to use our platforms in an easy way tailored to your interests and preferences.

Please review our Cookie Policy and learn more on how we use cookies or other tracking technologies.

9.  Data Security

We take reasonable steps to implement appropriate technical and organizational measures to protect your personal information. These measures are in compliance with applicable data protection and data security laws and are in place to prevent any risks, such as accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal information.

Our measures to protect your data include:

• limiting physical access to our premises;
• limiting access to personal information;
• requiring third-party providers to have acceptable security measures to keep personal information secure; and
• putting in place physical, electronic, and procedural safeguards in line with industry standards.

10.  Sharing your data with third parties

Nutrino does not sell or license your personal information to third parties.

We do not share your personal information with third parties except in specific cases, where an appropriate legal basis exists.  We may disclose your personal information to:

1. NUTRINO affiliates. NUTRINO as an international corporation might share your personal information with its several NUTRINO affiliates.
2. External service providers such as consultants, advisors and auditors. We may also share your data with trusted service providers who support us in providing you with services such as IT services, marketing, finance, advertising, archiving and document storage.
3. Business partners
4. Public or governmental authorities as required by applicable laws and regulations.

Where required by law, the appropriate data processing agreements have been concluded with these third parties.

11.  Data transfers outside the European Union

In some cases, we may transfer personal data to our affiliates, service providers or partners to third countries outside the EU.

In each case, we ensure that an appropriate level of data protection according to European standards according to Art. 46 GDPR is in place.

12.  Children

We do not intentionally or knowingly process personal information of children under the age of 16 or as otherwise defined by applicable laws.

If you are under the age of 16, talk to your parents or legal guardians and obtain their consent before sharing your personal information with us.

If you are a parent or legal guardian of a child under the age of 16, we ask that you supervise your children’s use of our products or services (including websites and other digital platforms) and make sure that your children do not and will not share any personal information with us without asking your permission.

13.  Your EU Data Privacy rights:

As a data subject, you have certain rights as relates to the processing of your personal data. These rights include the right to request:

• Access, modification of your personal information
• Deletion of your personal data (unless we are legally required to retain the information).
• Restriction of or objection to the processing of your information.
• A copy of your personal information in a structured, commonly used and machine-readable format

You may exercise these rights by contacting us directly.  All questions or requests regarding personal data should be sent to:

Address: 94 Yigal Alon, Alon Towers (2nd Tower), Tel Aviv

Telephone number: 972-72-2499111

E-mail: info@nutrinohealth.com

Upon receiving your request or questions, you will be asked to verify your identity and specify which kind of information you require.

Nutrino aims to ensure that your request will be addressed within one month and free of charge unless a disproportionate effort is required.

If you believe that the processing of your data is in conflict with the data protection legislation, you also have the right to contact your local data protection authority.

Our Data Protection Officer:

You also have the right to contact our data protection officer.

The contact details of our data protection officer are as follows:

Contact Data
Peter Suhren FIRST PRIVACY GmbH Konsul-Smidt-Straße 88 28217 Bremen	Tel.: 0421 696632-0 Fax: 0421 696632-11 E-Mail: office@first-privacy.com Web: www.first-privacy.com

Last updated: June 2018