PRIVACY POLICY
PRIVACY POLICY
Privacy Policy applicable to Personal Data collected on the Website
This page was last updated on April 25, 2024.
Article 1. Introduction and scope
This Privacy Statement (the "Statement") applies to Personal Data collected on the https://www.4gold .eu website (the "Website"), offered, owned and provided by:
Nutribam, a limited liability company under Belgian law, with registered office at Leeuwerikenlaan 5, 2390 Malle, registered with the Crossroads Bank for Enterprises under number 0674.721.904 (RPR Antwerp, Antwerp Branch) ; hereinafter referred to as "4Gold," "we" or "us"
4Gold considers the protection of personal privacy very important and wishes to inform, respect and give you - as a visitor to its Website - as much control as possible over what happens to your Personal Data and your privacy.
Your Personal Data and your privacy are protected by 4Gold in accordance with Belgian and European regulations, including Regulation (EU)2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "AVG"). Please read this statement very carefully. It describes not only your rights, but also how to exercise them.
Article 2. Contact details
4Gold is responsible for the Processing of your Personal Data that you make available through the Website and has the role of Controller for your Personal Data processed through the Website.
4Gold has appointed a data protection contact person to whom you can always turn for questions about your privacy and the processing of your Personal Data. The data protection contact can be reached at
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Nutribam BV |
Data protection contact |
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Lark Avenue 5 B-2390 Malle |
E-mail: privacy@4gold.eu Phone: +32477 76 29 23 |
Article 3. Definitions
Within the scope of the service, "personal data" qualifies as all information that we collect and process about our users that can be traced back to an identified or identifiable natural person. This term is to be understood broadly and includes, for example, your name, your date and place of birth, your cell phone number, your address as well as other information related to your physical, mental, economic or cultural condition when these can be linked to you. Exactly which Personal Data are all collected and processed by us is further explained below.
The "processing" of Personal Data means, inter alia, the automated operation or series of operations such as the collection, recording, organization, structuring, storage, updating or alteration, retrieval, consultation, use, dissemination or making available by any means, assembly, combination, archiving, erasure or ultimate destruction of Personal Data
All capitalized terms not defined in this Statement have the meaning defined in the AVG.
By visiting the Website, sharing your Personal Data and agreeing to this Statement, you expressly consent to the manner in which 4Gold collects and processes your Personal Data as described in this Statement.
Article 4. Principles of data collection
In processing your Personal Data, the following principles will be observed:
- The Personal Data is obtained and processed lawfully, fairly and transparently;
- Personal Data is processed only for specified, explicit and legitimate purposes;
- Care shall be taken to ensure that Personal Data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
- The Personal Data will be kept accurate and, where necessary, updated;
- Personal Data will not be kept longer than necessary for the purpose(s) for which it was obtained;
- Personal Data is kept safe and secure;
- We are responsible for and can demonstrate compliance with obligations under data protection legislation; and
- Respond to requests from data subjects to exercise their data protection rights;
Article 5. What Personal Data is collected and processed?
4Gold processes different types of Personal Data depending on the services you use on the Website. The Personal Data below are processed by 4Gold when you visit the Website:
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Profile information |
First name, last name, address, e-mail address, phone number, VAT number, company name, etc. |
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Financial Information |
bank account number, IBAN, etc. |
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Medical information |
Body substances (saliva, cheek mucosa, blood, bowel movements), raw physical and medical data (lifestyle data, i.e.: sleep pattern, sports, stress, eating habits, diet) |
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History and logs |
browsing behavior, date and time the Website was visited, date and time of registration on the Website, shopping cart information, etc. |
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Technical Information |
Data from computers, phones or other devices you use the Website with, your IP address, browser type, etc. |
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Cookies |
For more information, view our Cookie Policy |
When Personal Data of a third party is disclosed through the Website or for the purpose of visiting the Website, the person transmitting the Personal Data warrants that he or she has informed that third party and obtained all necessary consents to share the Personal Data of that third party through the Website.
Article 6. What is the purpose and basis of processing your Personal Data?
The purpose and basis of processing your Personal Data depends primarily on the category of Personal Data in question. Below is an overview of the purpose and basis of the various Personal Data we process.
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Profile information |
Target |
Profile data is collected when you create a profile on the Website, to process orders you place on the Website, to keep the Website functioning properly and to send emails regarding promotions, offers, products, etc. |
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Basic |
Performance of the contract and legitimate interest |
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Financial Information |
Target |
Financial information is collected by Mollie (the third-party, specialized provider and operator of payment services and payment platforms, as described in 4Gold's Terms and Conditions) for the processing of orders you place on the Website, specifically the processing of payments, etc. |
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Basic |
Performance of the contract and legitimate interest |
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Medical information |
Target |
Medical information is collected for performing your DNA and/or stool analysis and preparing the DNA summary report. Medical information is also collected for supplementing your existing DNA analysis and further tailoring the recommendations to your profile. |
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Basic |
Explicit consent |
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History and logs |
Target |
Data related to history and logs are collected to ensure d e proper functioning and personalization of the website, for analysis and to send you emails to "continue shopping" when certain products remain in your shopping cart. |
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Basic |
Legitimate interest |
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Technical Information |
Target |
Technical information is collected to personalize the Website and for location-based services. |
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Basic |
Legitimate interest |
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Cookies |
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For more information, view our Cookie Policy . |
Below we describe in detail each basis for Processing that applies:
The legitimate interest as a basis is justified with respect to technical information and history and logs since it is important for 4Gold to adapt and improve its Website based on that information. The fact that 4Gold processes this information also ultimately benefits users.
For some specific processing activities, we ask for your consent. The consent you give is free at any time and you have the right to withdraw it at any time. A withdrawal of consent does not affect the processing of Personal Data (i) prior to such withdrawal and - in the case of Personal Data for which another processing ground is available - (ii) based on a legitimate reason for processing Personal Data.
The above Personal Data may be provided directly by you, or may be collected by our business partners (e.g. contact details of healthcare companies) and/or customers (pseudonymized health and biometric data), or other third parties. The foregoing reasons may not be exhaustive, and 4Gold has the right to process your Personal Data for any other legitimate reason at any time. In such cases, 4Gold will notify you of that reason as soon as possible and, to the extent your consent is required, request your consent before commencing the processing. An update to this Statement may constitute such notice.
Article 7. Receiving and sharing personal data
4Gold receives your Personal Data, including when:
- you visit the website;
- you register on the Website;
- you contact 4Gold through the Website;
- you place orders through the Website;
- you provide medical records to 4Gold;
4Gold applies the principle of minimum data processing when processing your Personal Data and shares your Personal Data with third parties only when necessary for the proper functioning of the Website.
Processors and sub-processors of 4Gold always act under the responsibility of 4Gold. If 4Gold uses processors or sub-processors, this will always be done under a processor agreement that meets the requirements of the AVG and protects your Personal Data as much as possible. 4Gold thereby ensures that the processors and sub-processors have taken the required technical and organizational measures for processing your Personal Data.
Furthermore, 4Gold refrains from sharing or disclosing your data with third parties except in the cases listed below:
- Personal Data may be shared with third party service providers to whom 4Gold has outsourced certain processing activities. In any case, they will be limited to processing your Personal Data in accordance with our instructions and a data processing agreement will be concluded, obliging them to comply with all obligations imposed by applicable data protection legislation
- If required by applicable law or regulation.
Your personal information may be shared or transferred to the following entities and for the following purposes:
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Entity |
Responsibility |
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Google Analytics |
The Personal Data is transferred in order to optimize the Website. |
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Klaviyo |
Personal Data is transferred to send direct marketing messages. |
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Active Ants BV |
Personal Data is transferred to process your order through the Website. |
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Shopify payments |
Personal Data is transferred to process your order through the Website, including to process payment for your order. Shopify Payments is considered responsible for processing your financial data. |
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Mollie BV |
Personal Data is transferred to process your order through the Website, including to process payment for your order. Mollie is considered responsible for processing your financial data. |
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Laboratories and (genetic) experts |
The Personal Data is transferred to perform your DNA analysis and compile the DNA. |
This list will evolve and be updated regularly. An updated version will be made available when any changes are made.
If you are redirected via the Website to another website, platform or application, other terms and conditions, privacy and cookie policies may apply. You should be aware of the terms and conditions, privacy and cookie policies of those other applications, websites or platforms. We encourage you to read these terms and conditions, privacy and cookie policies of the other applications, platforms and websites you visit.
Article 8. Direct marketing
4Gold may use your Personal Data for direct marketing purposes in accordance with the restrictions thereon in the AVG to the extent you have given your consent. In this way 4Gold can keep you informed about its products, updates, events, etc. You may withdraw your consent at any time or object, free of charge, to the processing of your Personal Data for such marketing purposes.
For these direct marketing purposes, including profiling related to direct marketing, you have the right to object free of charge at any time by sending an e-mail to privacy@4gold.eu.
Article 9. Transfer of Personal Data to Countries outside the European Economic Area (EEA).
In principle, 4Gold does not transfer your Personal Data to countries outside the EEA. However, it is possible that 4Gold - through its sub-processors or processors - does transfer your Personal Data to countries outside the EEA. In this case, 4Gold will transfer your Personal Data outside the EEA only in accordance with applicable legislation (such as Chapter V of the AVG) (e.g. model contract clauses, binding corporate rules, codes of conduct, decisions declaring the level of protection to be appropriate, etc.). In doing so, 4Gold will impose on processors or sub-processors outside the EU the same obligations as those located within the EU in terms of technical and organizational protection of your Personal Data.
Section 10. How will my personal data be stored?
4Gold maintains the following retention periods for your Personal Data:
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Profile information |
Up to 5 years after you have made your Personal Data available on our Website, or a longer retention period if and as long as you do not delete your profile or 4Gold has a legitimate interest. |
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Financial Information |
The duration determined by Mollie and Shopify Payments. |
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Medical information |
Maximum 5 business days after you send an email to 4Gold confirming that you have received your DNA analysis by 4Gold. |
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History and logs |
Up to 5 years after you have made your Personal Data available on our Website, or a longer retention period if and for as long as 4Gold has a legitimate interest or is required to do so pursuant to a legal provision. |
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Technical Information |
Up to 5 years after you have made your Personal Data available on our Website, or a longer retention period if and as long as 4Gold has a legitimate interest or pursuant to a legal obligation. |
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Cookies |
For more information, view our Cookie Policy . |
Article 11. How will my Personal Data be protected?
4Gold has implemented appropriate technical and organizational measures and safeguards to process your Personal Data in accordance with applicable Belgian and European regulations, and in particular, without limitation, to protect your Personal Data from loss, misuse or unauthorized modification . 4Gold uses a team of technicians, automated systems and advanced technology such as:
- Secure Socket Layer (SSL) technology protects information through the use of server authentication and data encryption;
- Data is stored in a secure data center;
- All passwords are encrypted;
- Credit card or bank account information is processed by Mollie in accordance with secure protocols and other security measures established by Mollie;
- All transactions are processed through a gateway provider and are not stored or processed on our servers.
- Entering into processor agreements with suppliers;
- ...
4Gold makes all reasonable and appropriate efforts to maintain the confidentiality of your Personal Data.
Despite the above measures of 4Gold, you should be aware that there are always risks associated with the transmission of Personal Data over the Internet. The security and protection of your Personal Data can never be fully guaranteed.
Article 12. What rights do I have?
If and to the extent provided by applicable Belgian and European regulations, you have the right:
- to a confirmation as to whether or not 4Gold processes your Personal Data and, if applicable, access to the Personal Data that 4Gold processes;
- to correction by 4Gold, without undue delay, of inaccurate or incomplete Personal Data;
- To withdraw your consent to the processing of your Personal Data at any time;
- To have your Personal Data erased by 4Gold;
- To obtain and transfer your Personal Data to another controller or processor;
- to obtain from 4Gold the restriction of the processing of your Personal Data to the extent possible;
- To have your Personal Data transmitted in a structured, commonly used and machine-readable format;
to oppose the processing of your Personal Data and the use of your Personal Data, including for direct marketing purposes. You may exercise these rights by contacting the data protection contact person and providing him/her with a copy of the front of your identity card (no national registration number must be visible) or official other identification.
If and to the extent provided by applicable Belgian and European regulations, you have the right to lodge a complaint with the competent supervisory authority if the processing of your Personal Data violates applicable regulations. In Belgium, this is the Data Protection Authority
www.dataprotectionauthority.be
Press Street 35, 1000 Brussels
+32 (0)2 274 48 00
contact@apd-gba.be
Article 13. Amendments to the Declaration
4Gold may change this Statement at any time. The top right-hand corner of the Statement will display the date of the last amended version. Changes will be posted on the Website so that you are always aware of what information 4Gold collects, how 4Gold uses it, and how 4Gold shares it.
Amended versions of this Statement will take effect ten (10) days after publication on the Website and will be submitted for approval at any time, if necessary.
Article 14. Permission for release
You acknowledge, confirm and expressly agree that 4Gold may disclose your Personal Data if required to do so by law or if 4Gold determines in good faith that such disclosure is required in order to:
- comply with any ongoing judicial investigation, court order or legal process related to the website;
- respond to claims against 4Gold regarding Personal Data that violate the rights of third parties;
- protect the rights, property and safety of 4Gold, its employees, users and the public.
4Gold may disclose your Personal Data to competent police or judicial authorities or other government agencies if necessary or required in connection with an investigation of fraud, intellectual property infringement or any other harmful activity, or if 4Gold reasonably suspects that such activity may expose 4Gold or yourself to liability.
Article 15. Liability
If 4Gold has lawfully provided your Personal Data to a third party (other than a Processor or Subprocessor), 4Gold will not be liable for any unlawful processing or use by that third party.
Under no circumstances does 4Gold accept responsibility or liability for any direct or indirect damages resulting from any error or wrongful use of Personal Data by any third party (other than a Processor or Subprocessor).
4Gold is also not liable if third parties process or use your Personal Data unlawfully and 4Gold has taken appropriate technical and organizational measures to prevent such unlawful processing or use
Article 16. Applicable law and jurisdiction clause.
This Declaration shall be governed, interpreted and implemented in accordance with Belgian law, which is exclusively applicable to any dispute.
The courts of Antwerp, section Antwerp, Belgium, shall have exclusive jurisdiction to adjudicate any dispute that may arise from the interpretation or performance of this Declaration, subject to the consumer's right to submit a dispute to the competent court on the basis of a mandatory provision of law.