THE GUT STUFF APP PRIVACY POLICY

1. WHAT ARE OUR CONTACT DETAILS?

We are The Gut Stuff Ltd (“The Gut Stuff”, “we”, “us”, “our”) and we operate the mobile application (referred to as the “App”). Our full details are at the end of the policy. Our contact details are: [email protected]

The protection and security of your personal data is important to us. This privacy policy (“Privacy Policy”) tells you how we collect, use, share, and protect your Personal Data that is collected through the App.

2. WHAT PERSONAL DATA DO WE COLLECT?

We will process your personal data in the following ways:

App account: when you create an App account, we will collect your name, email address, date of birth and other registration data, such as your password. We may also collect your gender if you choose to provide it.

Health information: for the purpose of customising the App for your use, and to provide you with access to information you wish to see, you can provide your health information (such as medical information and data relating to your symptoms). If you do so, we will store this information in the App. You can also provide and store additional health and fitness data in the App (such as using the Gut Tracker feature to track your daily habits, symptoms and exercise).

User services: if you contact us about the App, we will keep a record of that contact. You may provide us with personal data when sending us your request. We will hold your email address in order to consider your request and respond to you.

Usage data: when you access the App with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers.

Information about your use of the app (for example, which sections of the app that you use).

If you use the shop on the app, you are transferred to our website; any information collected during the process of buying something is subject to our privacy policy on our website, and you should refer to that for information about what personal data is collected and what it is used for.

3. WHAT DO WE USE YOUR PERSONAL DATA FOR?

We will ask you for your explicit consent to the processing of your health-related information as described in this Privacy Policy, which you can withdraw at any time by contacting us at: [email protected].

We use the personal data we collect via our App for the following purposes:

To operate and administer our App.

We will use your personal data to perform our contractual obligations under our terms and conditions and when it is in our legitimate interests, such as,

Processing any request or enquiry you make in connection with our App;

Customising the App for your use, to provide you with access to information that you are looking for, to configure the App for your particular use (for example, to reflect subjects covered by the App which you are interested), and to provide you with information that you are trying to find (for example, to provide you with access to articles and other information you wish to see);

Enabling you to share your personal data with a healthcare professional;

Managing our relationship with you, which includes sending administrative information to you relating to our App and changes to our terms, conditions, and policies and App services generally.

Where required by applicable laws, when we process your sensitive data (such as, health data) we rely on your explicit consent.

To improve, monitor, personalise, and protect our App.

It is in our legitimate business interests to improve and keep our App safe, which includes:

Analysing and understanding how you use our App and to customise your relationship with us;

Conducting data analysis, testing and research, including for statistical purposes;
 
Protecting the security of and managing access to our App, IT and communication systems, online platforms and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities.

Where required by applicable laws, when we process your sensitive data (such as, health data) we will rely on your explicit consent.

For marketing and advertising purposes.

Sending you information about Gut Stuff’s promotions and offers which may be of interest to you. You may opt out of receiving our marketing communications by following the opt-out instructions in each marketing communication or at any time by contacting us at: [email protected].

To enforce our agreements, to comply with legal obligations and to defend us against legal claims or disputes.

We may use your personal data to comply with our legal obligations or when it is in our legitimate business interests, which includes:

Complying with our legal and regulatory obligations and requests, including reporting to and/or being audited or investigated by national and international regulatory bodies;
Complying with court orders and to exercise and/or defend our legal rights.

To facilitate corporate acquisitions, mergers or transactions.

We may use your personal data, when it is in our legitimate business interests, when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may share your personal data in the following ways:

Service providers: We may employ third party companies and individuals to facilitate the App, provide the services through the App on our behalf (such as data storage and hosting providers), assist us in analysing how the App is used, assist us with marketing.
Professional advisors: We may share your personal data with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Third party consultations: If you wish to book an appointment with a third party for a consultation through the App, we will share your personal data with the third party to arrange the appointment.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets. The recipient of the information will be bound by confidentiality obligations.
Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the App, or the public, or (v) protect against legal liability. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

5. HOW DO WE STORE YOUR PERSONAL DATA?

We primarily store your personal data in the European Economic Area and the United Kingdom. We may also transfer personal data to our service providers in the United States and in other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal data and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision/regulation for transfers outside of the European Economic Area and United Kingdom, or on contractual protections for the transfer of personal data. For more information about how we transfer personal data internationally, please contact us as set out in the “What Are Our Full Details” section below.

6. SECURITY OF YOUR PERSONAL DATA

We have implemented reasonable and appropriate administrative, technical and physical safeguards to protect the confidentiality, integrity, and availability of your personal data. We will use strict procedures and security features and take all steps reasonably necessary to ensure your personal data is processed securely and in accordance with this Privacy Policy.

You are responsible for protecting against unauthorised access to the App. You should use strong password security, by using a mix of letters, numbers and symbols and a different password than you use for any other accounts that you may have. You must keep your account password confidential and not share it with anyone.

We are not responsible for any lost, stolen or compromised passwords or for any access to your account from unauthorised users where such access is caused by your actions or inaction. If you think your account has been compromised, please contact us as soon as possible, using the contact details in the “What Are Our Full Details” section below.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. Information which you provide voluntarily will be retained for as long as you choose to store it in the App until it is deleted or you have deleted your account. We may also be required to maintain your information to meet legal requirements.

We also keep information about you and your use of the App for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described above. To determine the appropriate retention period for your 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.

8. WHAT ARE YOUR DATA PROTECTION RIGHTS?

You may be able to exercise the following rights:

Your right of access – you have the right to ask us for copies of your personal data; please note that, in relation to any information relating to you and your health that is stored by you on the App, you can access this yourself at any time via the App, and we cannot provide you with copies of the information ourselves, because it is encrypted and so only you have access to it.
Your right to rectification – you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – you have the right to ask us to erase your personal data in certain circumstances.
Your right to restriction of processing – you have the right to ask us to restrict the processing of your personal data in certain circumstances.
Your right to object to processing – you have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Please note that we may ask you to verify your identity before responding to such requests. Where you have been asked to consent to the processing of your personal data, you can withdraw consent, such as by contacting us using our contact details below. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Please also note that where you withdraw consent, we will only stop processing your personal data that relates to the withdrawal of consent.

Please contact us at [email protected] if you wish to exercise any of your rights. Additionally, you may have the right to complain to a data protection authority in your country about our collection and use of your personal data.

9. LINKS TO OTHER SITES

The App may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

10. CHILDREN’S PRIVACY

Our App does not target or address anyone under the age of 18 (“Children”).

We do not knowingly collect personal data from Children. If you are a parent or guardian and you are aware that your Child has provided us with personal data, please contact us using the details provided in the “What Are Our Full Details” section below. If we become aware that we have collected personal data from Children without verification of parental consent, we take steps to remove that information from our servers.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the App.

12. WHAT ARE OUR FULL DETAILS?

We are The Gut Stuff Ltd, a company registered in England with number 10848840, and our address is Elm Tree House, Handley Lane, Chesterfield, Derbyshire, S45 9AT. We are the controller of your personal data. You can contact us at: [email protected].

Effective data: 25 January 2024