Cura Nutrition Ltd. Revised privacy notice and policies, GDPR November 2020

 

  1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our website:

www.curanutrition.com

 

This includes any information that you may provide through our site when you purchase a product or service, sign up to our newsletter, register for a webinar or other training event, request information and sign up at various practitioner events, conferences and trade shows, or take part in a prize draw, award or competition where Cura Nutrition is giving away free products from any of brand ranges.

By providing us with your data, you warrant to us that you are over 16 years of age.

Our Business is called Cura Nutrition Ltd.

The owner of Cura Nutrition Ltd is TMC Ventures Europe Ltd. We are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

 

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details

The Data Protection Officer,        email questions to: [email protected]

  1. WHAT DATA MAY WE COLLECT ABOUT YOU?

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We do not collect any Sensitive Data about you.

Sensitive Data refers to data that 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

  1. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

 

 

 

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data as legally permitted. The most common uses of your personal data are:

 

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at [email protected] or, if received by MailChimp, simply click on unsubscribe

 

Purposes for processing your personal data

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.

You will receive marketing communications from us if you have:

 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at [email protected]

Where you opt out of receiving our marketing communications, 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.

 

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at [email protected]

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

Your information is only used by Cura Nutrition Ltd and our related companies TMC Ventures Europe Ltd and TMC Ventures Inc

Our policy is to never share your personal data with any third party for their marketing purposes.

Should that policy ever change we will proactively contact you and ask for your express permission before sharing any data with any 3rd parties.

 

  1. INTERNATIONAL TRANSFERS

 

We may share your personal data within the TMC Ventures group of companies which may involve transferring your data outside the European Economic Area (EEA)

 

Transfer to Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

 

Our third parties service provider (MailChimp) is based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

  1. DATA SECURITY

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.

In addition, we strictly limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. 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.

 

  1. DATA RETENTION

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 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.

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected]

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.

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.

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.

 

  1. THIRD-PARTY LINKS

At time of this publication (May 2018) NONE of our websites have links to any third-party websites, plug-ins and applications other than for secure payment processing.

Your information is only connected with Cura Nutrition Ltd and payment providers such as PayPal and Stripe.

At some future point, if links to other websites are established, clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We would not control any potential future third-party websites and would not be responsible for their privacy statements. If you leave our website, we encourage you to read the privacy notice of every website you visit.

 

  1. 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 HERE

 

This notice and policy is effective November 2020, in compliance with GDPR