Privacy Policy

Eat Well Global, Inc. and Eat Well Global B.V. (“Eat Well Global”, “we”, “us”, “our”) are committed to safeguarding the privacy of our website visitors at www.eatwellglobal.com (the “Site”).

The purpose of this Privacy Policy is to set out the principles governing our use of personal data that we may obtain about you through the Site and in connection with the provision of our services (the “Services”). By using this Site, you agree to our use of the personal data that we obtain about you.

Please read this Privacy Policy carefully. We may change our Privacy Policy from time to time. We therefore ask you to check it occasionally to ensure that you are aware of the most recent version that will apply each time you access this Site. If a revision meaningfully reduces your rights, we will notify you. BY USING THIS SITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THIS SITE.

For your convenience, this Site may contain links to a number of other websites. The privacy policies and procedures described here do not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies. Any reference to a linked site or any specific third party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.

 

How we use your personal data

In this section we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

We process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We may also use Google Analytics. The source of the usage data is our analytics tracking system. This usage data is processed for the purposes of analysing the use of the website. The legal basis for this processing is: (i) your consent, 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 or (iii) where we need to comply with a legal or regulatory obligation.

We process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters, which may include name, mailing address, email address, phone number, profession, areas of professional interest  and/or which tells us your preference in receiving marketing from us and our third parties and your communication preferences (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications, newsletters and/or other marketing communications. The legal basis for this processing is: (i) your consent, 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 or (iii) where we need to comply with a legal or regulatory obligation.

We may transfer your personal data  in the event of a business transaction involving the Company which may include a sale of the Company.

 

Sharing your data

We may share information as discussed below, but we won’t sell it to advertisers or third parties.

Others working for Eat Well Global. Eat Well Global uses trusted third parties (i.e. IT services, analytics services, etc.) to help us provide, improve, protect, and promote our Site and our Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions.

Other applications and third-party links. The Site 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 policies. When you leave our Site, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal data will be governed by their privacy policies and terms.

 

Protecting your data

We only process personal data where we have a legal basis for doing so. We review the personal data we hold on a regular basis to ensure it is being lawfully processed.

Before transferring personal data to any third party (e.g. suppliers, partners and back office support), we establish that there is a legal reason for making the transfer, which may include your consent.

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 unauthorized 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.

We have implemented measures and procedures that adequately protect the privacy of individuals and ensure that data protection is integral to all processing activities. This includes implementing measures which may include:

  • Data minimization (e.g. not keeping data for longer than is necessary);
  • Pseudonymization;
  • Anonymization;
  • Cyber security; and
  • A data security policy.

 

International transfers of your personal data

The hosting facilities for our website are situated in the United States of America. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted and approved by the European Commission.

Personal data is being shared in our two locations, safeguarded by standard data protection clauses adopted and approved by the European Commission:

Eat Well Global B.V.
Overamstelstraat 37
1091TM Amsterdam
The Netherlands

AND

Eat Well Global, Inc.
405 2nd Street
Brooklyn, NY 11215 USA

Eat Well Global makes no representation that materials on this Site are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited.  Those who choose to access this Site from other locations do so on their own initiative and are responsible for compliance with applicable local laws.

 

Retaining and deleting personal data

We comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

  • Usage data will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 2 years after which it will be deleted or anonymized;
  • Notification data will be retained for a period of 1 year following the date that we are instructed to cease sending the notifications;

 

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

We use cookies for the following purposes:

  • Authentication and status – we use cookies to identify you when you visit our website and as you navigate our website. cookies used for this purpose are identify cookies;
  • Analysis – we use cookies to help us to analyse the use and performance of our website and services cookies used for this purpose are identify cookies and
  • Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally, cookies used for this purpose are identify cookies.
  • We use Google Analytics — Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/and you can review Google’s privacy policy at https://policies.google.com/privacy. The relevant cookies are identify cookies.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies on the browsers’ websites.

Eat Well Global currently does not respond to Do Not Track requests.

 

Your rights – individuals in the European Union

If you are an individual in the European Union or other jurisdiction with similar rights, you have certain rights with respect to the access, correction, restriction, and erasure of your personal data stored by us at any time. You can exercise any of these rights at any time by contacting us via the contact information below. Your rights include the following:

  • Accessing your data. Upon request, we shall provide any information relating to your data and our processing of your data in a concise, transparent, intelligible, and easily accessible form using clear and plain language. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within 30 days of a written request.
  • Correcting your data. You have the right to ask us to rectify any inaccurate or incomplete personal data on our platform. If we have given your personal data to any third parties, we will notify those third parties that Eat Well Global has received a request to rectify your personal data, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however, we are not in a position to audit those third parties to ensure that the rectification has occurred.
  • Erasing your data. You can ask us to erase your personal data stored by us. If we receive a request to erase your data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data we have erased so you may be contacted again by us, should we come into possession of your personal data at a later date.

If we have given your personal data to any third parties, we will tell those third parties that Eat Well Global has received a request to erase your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold – however, Eat Well Global will not be in a position to audit those third parties to ensure that the rectification has occurred.

Restricting the use of your data. We only process your personal data where we have the legal basis for doing so. You have the right to ask us to suspend or otherwise restrict the processing of your personal data where:

  • You challenge the accuracy of the personal data;
  • The processing is unlawful but you do not want us to erase it;
  • We no longer need the personal data for the purposes of the processing, but you want us to hold it as you need it to establish, exercise, or defend legal claims; or
  • You have objected to our use of your data, but we need to verify whether we have legitimate grounds to use it.

If we have given the personal data to any third parties, we will tell those third parties that we have received a request to restrict the use of your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold – however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.

Withdrawing your consent. Where we are relying on consent to process your personal data (for example consent to receive marketing) you have the right to withdraw your consent at any time. 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 services to you.

 

Your privacy rights – California consumers

Accessing Account Information. We will provide you with the means to ensure that personally identifiable information in your web account file is correct and current. You may review this information by contacting us by via the contact information below.

California Online Privacy Protection Act. As required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through our Site about individual consumers who use or visit our Site and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

California Consumer Privacy Act of 2018 (CCPA). You have the right to request, twice a year and free of charge, certain information about parties to whom we have disclosed or sold your personal data in the prior calendar year and a description of the categories of personal data shared. Additionally, upon request, twice a year and free of charge, we shall provide to you any information relating to your personal data and our processing of your personal data in a concise, transparent, intelligible, and easily accessible form using clear and plain language. To make such a request, please send an email to [info@eatwellglobal.com] and please include the phrase “Personal Information Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address.

You can also ask us to delete your personal data stored on our platform. If we receive a request to delete your data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose personal data we have deleted so you may be contacted again by us, should we come into possession of your personal data at a later date.

If you exercise your rights under the CCPA, Eat Well Global will not discriminate against you. Requests to know and requests to delete will be honored within 45 days; if more time is needed to respond, Eat Well Global will notify you. You can use an authorized agent to make a request on your behalf.

Eat Well Global has collected, will collect and has disclosed the personal data described in the categories below during the last year for business purposes; however, Eat Well Global does not sell your personal data.

This information includes:

  • Category A: Identifiers, including name, postal address, online identifier, email address.
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including name, address, telephone number, current employer and job title.
  • Category F: Internet or other similar network activity, including browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Category I: Professional or employment-related information, including current employer and job title.

 

Amendments

We may update this policy from time to time by publishing a new version on our website.

 

Our details

Eat Well Global B.V.
Overamstelstraat 37
1091TM Amsterdam
The Netherlands

Eat Well Global, Inc.
405 2nd Street
Brooklyn, NY 11215
USA

Privacy contact e-mail: info@eatwellglobal.com