1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Nutrition Choices collects and processes your personal data through your use of this website, including any data you may provide through this website, including for example, when you join our Membership.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
ActiveCampaign is the Processor of the personal data we hold and that is provided to us when you subscribe to our Mailing List upon joining our Membership.
Practice Better is the Processor of the personal data we hold and that is provided to us when you book a session with us.
Stripe is the Processor of the personal data we hold and that is provided to us when you sign up to our Membership.
Patricia Daly, trading as Nutrition Choices, is an experienced and internationally recognized Nutritional Therapist (BA Hons, dipNT, mBANT, rCNHC), specialising in the area of Integrative Cancer Support. This privacy notice is issued on behalf of Nutrition Choices so when we mention “we”, “us” or “our” in this privacy notice, we are referring to Nutrition Choices responsible for processing your data. Nutrition Choices is the controller and responsible for this website.
If you have any questions about this privacy notice, including any requests to exercise legal rights, please contact the Controller’s Data Manager using the details set out below.
Our full details are:
Full name of legal entity: Nutrition Choices
Name or title of Data Manager: Patricia Daly
Email address: admin @ ketoforyou.com
Postal address: The Mews, 2 Mountain View Road, Ranelagh, Dublin, Ireland
Your duty to inform us of changes
If you are a member of this site, you can also check and update your data by logging in with your email address or username and clicking on your Profile link at any time.
If you have submitted personal information through our website and would like that information deleted from our records or would like to update or correct that information, or if you wish to raise a complaint on how your personal data is handled, you can contact the Controller’s Data Manager who will investigate the matter. You may also have a right to receive the information in a structured, commonly used and machine-readable format and transfer or have this information transferred to another data controller.
The Data Manager is Patricia Daly and you can contact them using the email address above. Please mark your email / correspondence “For the attention of the Data Manager”.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes your name and gender.
- Contact Data includes your email address.
- Financial Data includes financial information should you enter into a contract for the supply of services with Nutrition Choices.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Unless you have entered in to a contract for the supply of services with us, we do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
We use different methods to collect data from and about you including:
- Direct interactions - We obtain information from you when you use our website, for example:
- by filling in forms on our website(s);
- when you register to our Membership by establishing an Account, signing up to our Mailing List through the Membership, booking a session with us;
- or by corresponding with us by phone, e-mail or otherwise.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have subscribed to our Mailing List via the Membership.
- correspond to your enquiry email;
- to carry out our obligations arising from any contracts entered into by you and us;
- to improve membership service (your information helps us to more effectively respond to your membership requests and support needs);
- dealing with entries into a competition;
- seek your views or comments on the services we provide;
- notify you of changes to our services;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation
Purposes for which we will use your personal data
We collect your personal data when you subscribe via this Website to our Mailing List or contact us via the website. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose / Activity||Type of data||Lawful basis for processing including basis of legitimate interest
|To register you as a subscriber on our Mailing List as part of our Membership||(a) Identity |
|Performance of a contract with you
|To process and deliver Newsletters as part of our Membership||(a) Identity |
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests
|To manage our relationship with you||(a) Identity |
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)
(d) Necessary when entering into a contract for the supply of services with us
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you||(a) Identity |
|Necessary for our legitimate interests (to study how customers use our website)
|To use data analytics to improve our website, customer relationships and experiences||(a) Technical |
|Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business)
Choice and transparency
Every email we send through ActiveCampaign will include an opt out link for any email newsletters.
You can unsubscribe from our Mailing List by contacting us at any time or by clicking on the “Unsubscribe” button in the Newsletter footer.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We will not sell or rent your information to other third parties.
We will not share your information with third parties for marketing purposes.
6. International transfers
When subscribing to our Mailing List, all personal data is processed in the USA by us and our subcontractors and only in connection with the services provided to the Controller.
When signing up to our Membership, all personal data is processed in the USA by us and our subcontractors and only in connection with the services provided to the Controller.
The Controller and Processor have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
No automated decision making is made using your personal data.
7. Data security
We implement a variety of security measures to maintain the safety of your personal information when you sign up to our Membership or access your personal information.
We offer the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorised with special access rights to such systems, and are required to keep the information confidential.
After a transaction, your private information (credit cards or financials, etc.) will not be stored on our servers. We DO NOT handle any of your financial (credit card) information, all that information is handled securely by Stripe. We do store some limited information about your online transaction (Paid Subscriber transaction ID) which is held against your User ID for our Financial Records.
8. How long will you use my personal data for?
We retain your personal data for as long as your Controller has a relationship with you and the data is required to support the service.
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.
In some circumstances you can ask us to delete your data: see Request erasure below for further information. You may also choose to delete your Account with us by navigating to your Profile page located under the 'Profile > My Account' and clicking on the 'Delete Account' link.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract (eg: a subscription) to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- ActiveCampaign - Service providers acting as processors based in the USA who assist with managing our Mailing List.
- Stripe - Service providers acting as processors based in the USA who assist with payment transactions.
- Practice Better - An electronic practice management tool which stores health records, appointment information, and communication between practitioners and clients.