PRIVACY POLICY
Introduction
We strive to protect the personal data that we may collect about our users, under our control and take certain precautions to help maintain the security and accuracy of the data. When you use this website, you trust us with data about you. Subsequently, you may provide us with personal data. Because your privacy is important to us, we recommend you read this privacy policy (“Privacy Policy”) so that you understand our approach towards the use of your personal data and contact us if you have any questions.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please also note the below section on our use of cookies. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who are we
NutriCalc Limited (“us” or “we”) are committed to protecting and respecting your privacy. For the purposes of data protection law, the data controller with conduct of your personal data is NutriCalc Limited. NutriCalc has its registered office at Birchin Court, 5th Floor, 19-25 Birchin Lane, London, UK, EC3V 9DU and registered No. 08490867.
Applicable scope
References in this policy to “data protection law” mean (as applicable) UK General Data Protection Regulation, the Data Protection Act of 2018, the Privacy and Electronic Communications Regulations and all related data protection legislation having effect in the United Kingdom as well as the EU General Data Protection Regulation, the ePrivacy Directive and all related data protection regulation that have an effect in the European Economic Area.
References in this policy to the “application” mean, applicable, the NutriCalc software.
This statement applies only to the platforms that are owned by the NutriCalc. We are not responsible for the privacy practices of other sites and (online) resources available on our platforms. If you have any questions about this privacy policy or have a complaint about the way in which we deal with your personal data you can contact enquiries@nutricalc.co.uk.
The data controller
NutriCalc is responsible for the processing of your personal data. This means that NutriCalc determines the purpose and means of the processing itself and that NutriCalc is responsible for regulatory compliance.
Acquisition by TraceGains
NutriCalc has been acquired by TraceGains. As such, NutriCalc is now part of TraceGains. TraceGains is a Delaware corporation with offices at 12303 Airport Way, Bldg. I, Ste. 180, CO 80021. To learn more about them, please click here.
Data migration from NutriCalc to TraceGains
The CRM (customer relationship management) system of NutriCalc will be permanently deleted. Consequently, the data contained in the CRM system of NutriCalc will be migrated into the CRM system of TraceGains. The legal basis for this form of processing is legitimate interest; we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information in this way. Since the CRM system of NutriCalc will be permanently deleted, to be able to continue to effectively and efficiently service you and your account – provide support – when requested, it is necessary that the data is migrated. There is no realistic and viable alternative. Your data is migrated via an encrypted file with password protection after which it is stored into CRM system of TraceGains. To learn more about the technical- and organizational measures of TraceGains, please click here.
If you have any questions about the acquisition and/or the data migration, feel free to contact us via enquiries@nutricalc.co.uk.
What is personal data
Personal data is any information about an identified or identifiable natural person. Each piece of information with which a person can be identified, directly or indirectly, is personal data. This could be for example your name, contact details and any other information that is or can be linked to you, including, for example, email address, location information, login code, health data, bank details, etc.
What falls under processing of personal data is defined as any act or set of acts related to or performed on personal data. This could, for example, be collecting, using, transferring, and saving.
Methods of collecting information
Directly: when you contact us, filling in forms on our website, entering that information into the application or by corresponding with us by phone, e-mail or otherwise, attend an event, choose to provide data to us (for example by submitting a contact form via the website), use our services in any way, browse our website, when you submit content and/or engage with us on social media. It includes information you provide when you register to use our site or the application, subscribe to a service we provide (including the application), place an order on our site and when you report a problem with our site or application to us, submit your CV/resume and/or attend an interview.
Indirectly: we may collect personal data from publicly available data relating to your job title, education, and employment such as registration with professional bodies, qualifications, and commercially available sources, for example from social media sites such as LinkedIn, public job boards, trade organizations, trade events, advertisements, B2B contact database, or other public sources.
There is also data we collect via other parties. This is usually only the case where your details are passed to us by another member of your organization or, if you are a sole trader or partner in a legal partnership, by our employees or fellow partners. This will typically comprise your name and contact information.
Personal data elements
We process the following types of information, including data that relates to identified or identifiable individuals (note, specific personal data elements listed in each category may change):
- Identity data: personal data about you and your identity, such as your name, date of birth, residence address, username, company affiliation and title, and other you provide in the context of using our services or as part of an account profile and any other information you insert into your account.
- Contact Data: data used to contact an individual, e.g. email address(es), physical address(es), phone number(s) any other information you provide to us when communicating.
- Transaction Data: personal data we collect in connection with a transaction or purchase, such as subscription information, price, and other similar information.
- Payment Data: information such as bank account details, payment card information, and information from credit reference agencies.
- Professional Data: personal data relating to your employment or profession.
- Website Data: technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform. Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
- Submitted Job Application Data: your CV, resume, transcripts, and any supporting documentation attached to your resume such as copies of certificates and diplomas and other information you submit.
- Interview Related Data: obtained while conducting a phone interview, video interview, in-person interview, or interview through one of our third-party interview and recruitment service providers. Reference Check Data: such as a verification of your educational and professional background, and other relevant data subject to NutriCalc policies and applicable laws.
- Application Data: with regard to your use of the application, we will automatically collect information about how you use the application in addition to the information we collect when you visit our site. This includes application response times, application interaction information, error information, the duration of your usage, and usage history.
Using the personal data
We use information held about you in the following ways:
- To carry out our obligations arising from any contracts entered into between you (or the organization you work for or represent) and us. For customers, this includes providing you (or your organization) with the information, products and services that you request from us and managing your account with us. For suppliers this includes us obtaining price quotations from you and engaging you (or your organization) to supply us products and services;
- To optimize and improving our services;
- To provide you with our services;
- To contact you and/or provide you with support when you have requested us to do so;
- To communicate with you in the context of a job application, planning an interview and sending you such invitations;
- To review the personal data that you provided in the context of a job application;
- To share information with our internal staff members, for example, in the context of job application purposes.
- To communicate with you about important things regarding your account and/or purchases;
- To send direct marketing, provided that you consented to this;
- In the case of customers (or employees or representatives of customer organizations), to notify you about changes to our service and the application;
- In the case of customers (or employees or representatives of customer organizations), to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- To monitor usage of the application in order to improve its functionality. To otherwise respond to your enquiry or follow up our own enquiries;
- To ensure that the application and content from our site is presented in the most effective manner for you and for your computer;
- To administer our site and the application, including for troubleshooting, data analysis, testing, research, statistical and survey purposes.
Legal grounds for processing
We will only process your information when we have a lawful basis for doing so. There are various legal bases contained within the (UK) GDPR on which we can rely. We are processing your data on the following grounds:
- If you are a customer or supplier of ours, our lawful basis for the processing is the performance of the contract between you and us, including the taking of pre-contractual steps at your request;
- If you are an employee or representative of a customer or supplier of ours, the lawful for the processing is the performance of a contract between us and your employer or principal, including taking pre-contractual steps at their request and our legitimate interest. In accordance with data protection law, we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information in this way.
- In certain circumstances, the processing is necessary for us to comply with our legal or regulatory obligations. For example, tax purposes;
- We are otherwise processing your data on the basis of your consent. This will typically be the case where you have opted into receiving marketing communications from us. If consent is the legal basis, then, you are always permitted to revoke your consent at any time. In order to do so, please send an email to enquiries@nutricalc.co.uk.
- In all other cases, the processing is necessary for achieving our legitimate interests such as but not limited to:
- Optimizing and improving functionality of our services and website;
- Making sure that our services are secure and operate effectively;
- Maintaining accurate internal records of customers, suppliers, contractors and their contacts for administrative and commercial purposes. This includes where we keep a record of potential supplier details with a view to using their services or purchasing their products in the near future;
- Responding to your enquiry, whether submitted through our website, email, over the telephone, in person or otherwise;
- Sending you marketing information about our products and services about products that you have already purchased and are similar to that which you already purchased (including, where applicable, on the basis of the soft opt- in under the Privacy and Electronic Communications Regulations and the ePrivacy Directive). You can unsubscribe from these communications at any time by following the instructions contained in the communication or by contacting us using the details set out below.
In accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes.
Marketing communications/ newsletter
You can subscribe to the newsletter of TraceGains/NutriCalc via https://tracegains.com/. Through the newsletter we keep you informed with news about our company and relevant offers. In every newsletter that you receive, there is a link with which you can unsubscribe from receiving this newsletter.
Retention term
We will keep your personal data to enable your continued use of our services, for as long as necessary in order to fulfil the relevant purposes described in this privacy policy or as is required by law.
Data disclosure
We use third parties to manage our services. It is possible that these third parties have access to your personal data. If that is the case, we take appropriate measures to ensure that your data is adequately secured and used exclusively for the intended purposes. When dictated by law, we conclude – amongst others – data processing agreements with these parties qualifying as processors to ensure that they offer the same level of protection that the law requires. Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to carry out the requested services or to efficiently operate our business. In order to achieve these purposes, we will share your data with the following people or groups of people:
- Business partners, service providers and other affiliated third parties: to enable us to provide our services to you, we may need to share your personal data with our business partners and external service providers;
- Our outsourced IT providers. Our IT providers may in certain circumstances require access to data held on our systems, for example when we need to troubleshoot a technical issue. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times;
- Potential purchasers of our business, subject to those persons entering into strict confidentiality obligations with us and only to the extent permissible under data protection law;
- Our professional advisers, such as our accountants and solicitors, who are subject to professional duties of confidentiality;
- Disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Data under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
Additionally, internal selected personnel from NutriCalc have access to certain personal data, insofar necessary in the execution of their work/work. The selected personnel are bound by confidentiality. TraceGains: NutriCalc has been acquired by TraceGains. As such, we are now part of TraceGains. Personal data in NutriCalc CRM system is migrated to TraceGains CRM system. The selected personnel who have access to that data are bound by confidentiality.
Transferring personal data outside of the European Economic Area and/or the United Kingdom
Information we collect from you will be processed by our contracted third parties, with whom we have a contractual agreement. Contracted third parties may be processing your personal data within and outside the European Economic Area (EEA) and/or the United Kingdom (UK).
When personal data is transferred outside of the EEA and/or the UK by us, we make sure that the appropriate supplemental safeguards are in place to ensure an adequate level of the protection of your data in accordance with the General Data Protection Regulation (GDPR).
Where necessary, we will (or have already) entered into standard European Commission approved model data protection clauses (Standard Contractual Clauses) for transfers from the EEA and/or the International Data Transfer Agreement Addendum for transfers from both the EEA- and the UK or the full International Data Transfer Agreement when there are solely UK data subjects involved with the contracted third parties who are located outside the EEA, so we can provide you with the required service and with our external service providers and business partners in relation to services that they may provide that involve data processing from locations outside the EEA and/or UK for which we are the data controller.
Automated decision making
We do not make automated decisions about you based on your information. If this changes in the future then we will let you know.
Security
To help protect the personal data that you transmit through usage of NutriCalc’s services, we maintain physical, technical and administrative safeguards. We update- and test our security technology on an ongoing basis. We restrict access to your personal data only to selected and authorized staff members who need access. In addition, we train our staff members about the importance of confidentiality and maintaining the privacy and security of your information.
Furthermore, when engaging with third-parties who are classified as processors, we make sure to always conclude data processing agreements with such parties and we put in place strict confidentiality obligations with our third party service providers.
Your rights
The (UK) GDPR provides you with the following rights:
- The right of access. This means you can make a request to obtain access to the personal data concerning you;
- The right to rectification or correction of your personal data;
- The right to erasure of the personal data concerning you;
- The right to restriction of the processing. This means you can ask us to restrict the processing of your personal data in some circumstances, such as when you contest the accuracy of the personal data;
- The right to data portability. This means that you have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- The right to object. This means you can object to our processing of your personal data and ask us to stop such processing at any time if we rely on our own or someone else’s legitimate interests to process your personal data or where we process your personal data for direct marketing purposes.
- Right to object to automated decision-making. This means you have the right not to be subject to a decision based solely on automated processing, including profiling. We do not use such automated decision-making in relation to our processing of your personal data described in this privacy statement.
- The right to withdraw your consent. If we rely on your consent for the processing of your personal data, such as with receiving our newsletters, you have the right to withdraw that consent at any time via enquiries@nutricalc.co.uk.
If you have any questions or wish to exercise one of your rights, please contact us at enquiries@nutricalc.co.uk. Reasonable access to your personal data will be provided at no cost to you upon submitting a request to enquiries@nutricalc.co.uk within one month of acknowledgement of the request. To confirm your identity, we might ask you to provide additional information in order to fulfill your request.
If we cannot fulfill your request within one month, we will inform you about an expected data on which the information will be provided. Furthermore, we may require more information to verify your identification before fulfilling your request.
You also have the right to lodge a complaint with a supervisory authority. In the UK the supervisory authority is the Information Commission Office (ICO) and in the EEA this depends on the Member State.
Changes and updated to this privacy statement
From time to time we may make changes to this privacy policy. If we make any substantial changes to this privacy policy and the way in which we use your personal data, we will make sure to contact you directly. Please review our privacy policy on a regular basis.
Cookies and similar technologies
Information about our use of cookies
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive. Both our site and the application use cookies to distinguish you from other users. This ensures we can provide you with an optimal user experience and allows us to improve our site and the application. By continuing to browse the site or use the application, you are agreeing to our use of cookies.
Strictly necessary cookies
These are cookies that are required for the operation of our site and/or the application. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
Analytical/performance cookies
These allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. Additionally, these types of cookies allow us to monitor how our customers are using the application. This helps us to improve the way our site and the application work, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies
These are used to recognize you when you return to our site and/or the application. This enables us to personalize our content for you, greet you by name and organization and remember your preferences (for example, your choice of language or region or more technical settings in the case of the application).
Targeting cookies
These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site more relevant to your interests. We may also share this information with third parties for this purpose. Except for essential cookies, all cookies will expire after 30 [thirty days].
Third party cookies
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services and payment processing services) may also use cookies over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
Blocking cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) then you may not be able to access all or parts of our site or the application.
How to contact us
We value your opinions and feedback. If you have any questions, comments or concerns regarding our privacy policy or data protection, please send them to enquiries@nutricalc.co.uk or via post to NutriCalc Limited, Birchin Court, 5th Floor, 19-25 Birchin Lane, London, UK, EC3V 9DU.
You are entitled to contact us at any point to request what personal information we might hold about you and instruct us to remove it from our records if required:
NutriCalc Limited, Birchin Court, 5th Floor, 19-25 Birchin Lane, London, UK, EC3V 9DU.
Effective Date: 24-01-2024
Version number: 2.0