PRIVACY POLICY

PRIVACY POLICY

This Privacy Policy was last updated in August 2026.

Article 1. Introduction and scope

This Privacy Policy (the "Privacy Policy") explains how Nutribam, a limited liability company under Belgian law, with registered office at Wechelsebaan 73A, 2275 Lille, Belgium, registered with the Crossroads Bank for Enterprises under number 0674.721.904 (RPR Antwerp, Antwerp division), operating under the trade name 4Gold ("4Gold", "we", "us" or "our"), processes personal data.

This Privacy Policy applies to the processing of personal data collected through the website https://www.4gold.eu (the "Website"), the 4Gold webshop, when you purchase or use 4Gold products and services, when you subscribe to our Gut Support subscription, when you contact us, or when you otherwise interact with 4Gold.

4Gold considers the protection of your privacy and personal data to be important. We process your personal data in accordance with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

This Privacy Policy explains:

  • what personal data we collect;
  • why we collect and use your personal data;
  • the legal bases for processing your personal data;
  • with whom we may share your personal data;
  • how long we retain your personal data;
  • how we protect your personal data; and
  • which rights you have regarding your personal data.

For the personal data processed by 4Gold in connection with the Website, webshop, products and services provided directly by 4Gold, 4Gold is the data controller within the meaning of the GDPR.

DNA analysis offered through 4Gold

4Gold may offer customers the possibility to purchase a DNA analysis provided by Superhlth.

The DNA analysis, including the collection, analysis, interpretation and provision of genetic information, is a service provided by Superhlth. Superhlth is the relevant contact party for the DNA analysis and is responsible for the processing of personal data in connection with that service, to the extent specified in Superhlth's own privacy documentation.

4Gold does not itself perform the DNA analysis and does not act as the laboratory or genetic analysis provider.

Where you purchase a DNA analysis through 4Gold, certain personal data may be exchanged between 4Gold and Superhlth to enable the purchase, administration and provision of the DNA service. For the processing of your genetic data and other personal data by Superhlth in connection with the DNA analysis, Superhlth's own privacy policy applies.

Genetic data and health data receive enhanced protection under the GDPR and are considered special categories of personal data.

We therefore recommend that you carefully review Superhlth's privacy policy before purchasing or using the DNA analysis.

Article 2. Definitions

For the purposes of this Privacy Policy:

"Personal Data" means any information relating to an identified or identifiable natural person.

"Processing" means any operation performed on Personal Data, such as collection, recording, organisation, storage, consultation, use, disclosure, alteration or deletion.

"Customer" means any natural or legal person purchasing products or services from 4Gold.

"Website" means the 4Gold website available at https://www.4gold.eu.

"Webshop" means the online shop operated by 4Gold through which Products and Services are offered.

"Products" means the products offered by 4Gold through the Webshop.

"Services" means services offered directly by 4Gold, including the Gut Support subscription and other services offered by 4Gold from time to time.

"DNA Service" means the DNA analysis offered through 4Gold and provided by Superhlth.

Article 3. Principles of data processing

When processing your Personal Data, 4Gold complies with the principles established by applicable data protection legislation.

In particular:

  • Personal Data is processed lawfully, fairly and transparently;
  • Personal Data is collected for specified, explicit and legitimate purposes;
  • only Personal Data that is adequate, relevant and necessary is processed;
  • reasonable measures are taken to keep Personal Data accurate and up to date;
  • Personal Data is not retained for longer than necessary;
  • appropriate technical and organisational measures are taken to protect Personal Data; and
  • 4Gold respects the rights granted to data subjects under applicable data protection legislation.

Article 4. What Personal Data do we collect?

Depending on how you interact with 4Gold, we may process different categories of Personal Data.

4.1 Identification and contact information

This may include:

  • first name and surname;
  • billing and delivery address;
  • e-mail address;
  • telephone number;
  • company name;
  • VAT number;
  • account information; and
  • other information you provide when contacting us.

4.2 Order and transaction information

When you purchase Products or Services, we may process:

  • products ordered;
  • order number;
  • order date;
  • delivery information;
  • billing information;
  • purchase history;
  • discount codes;
  • subscription information;
  • returns and refunds; and
  • information relating to customer service requests.

4.3 Payment information

Payments are processed through external payment service providers, such as Mollie and/or Shopify Payments, depending on the payment method used.

4Gold does not normally have access to or store complete payment card details.

Payment providers process payment information in accordance with their own privacy policies and applicable legislation.

4.4 Technical and usage information

When you use our Website, we may process technical information such as:

  • IP address;
  • browser type;
  • operating system;
  • device information;
  • date and time of Website visits;
  • pages visited;
  • referring website;
  • Website interactions; and
  • other technical information necessary for the functioning, security and improvement of the Website.

4.5 Marketing and communication information

Where applicable, we may process:

  • your e-mail address;
  • marketing preferences;
  • information concerning your interaction with our marketing communications;
  • products or categories in which you have shown an interest; and
  • information used to personalise marketing communications.

4.6 Information relating to subscriptions

If you subscribe to a 4Gold subscription, including the Gut Support subscription, we may process:

  • subscription type;
  • subscription start date;
  • subscription status;
  • billing and payment information;
  • delivery information;
  • cancellation information; and
  • information necessary to administer the subscription.

4.7 DNA-related information

4Gold may facilitate the purchase of a DNA analysis provided by Superhlth.

Genetic data and information derived from a DNA analysis may constitute special categories of personal data under Article 9 GDPR.

4Gold does not itself perform the DNA analysis.

To the extent that Superhlth processes genetic data, biological samples or health-related information in connection with the DNA Service, that processing is governed by Superhlth's privacy documentation and applicable data protection legislation.

4Gold only processes the information necessary for its own activities, such as processing the purchase, administration, customer support and communication relating to the DNA Service.

4.8 Cookies

We use cookies and similar technologies on our Website.

Further information can be found in our Cookie Policy.

Article 5. Why do we process your Personal Data?

The purposes and legal bases for processing depend on the type of Personal Data and the context in which it is collected.

5.1 Processing and delivering orders

We process Personal Data in order to:

  • process your order;
  • process payments;
  • deliver Products;
  • manage returns and refunds;
  • provide customer support; and
  • communicate with you regarding your order.

The legal basis is generally the performance of the contract.

5.2 Managing subscriptions

We process Personal Data to establish and administer subscriptions, including the Gut Support subscription.

This includes:

  • processing subscription payments;
  • managing deliveries;
  • communicating about your subscription;
  • processing cancellations; and
  • providing customer support.

The legal basis is generally the performance of the contract.

5.3 Customer communication

We may process Personal Data to respond to questions, complaints, requests and other communications.

The legal basis may be the performance of the contract, compliance with a legal obligation, or our legitimate interest in properly managing our customer relationships.

5.4 Website operation and security

We process technical information to:

  • operate the Website;
  • maintain its security;
  • prevent fraud and abuse;
  • diagnose technical problems; and
  • improve the performance and functionality of the Website.

Depending on the circumstances, the legal basis may be our legitimate interest, compliance with a legal obligation, or consent where required.

5.5 Marketing

Where permitted by applicable legislation, we may use your Personal Data to send you information about:

  • 4Gold Products;
  • promotions;
  • new products;
  • events;
  • campaigns;
  • educational content; and
  • other marketing communications.

Where consent is required, we will only send such communications after obtaining your consent.

You may withdraw your consent or object to direct marketing at any time.

Article 6. Legal bases for processing

Depending on the processing activity, 4Gold relies on one or more of the following legal bases under the GDPR:

Performance of a contract

We may process Personal Data where this is necessary to perform a contract with you, for example to process and deliver an order or administer your subscription.

Legal obligation

We may process Personal Data where this is necessary to comply with legal or regulatory obligations, including accounting, tax and consumer protection requirements.

Legitimate interest

We may process Personal Data where this is necessary for our legitimate interests, provided that these interests are not overridden by your fundamental rights and freedoms.

This may include:

  • securing our Website;
  • preventing fraud;
  • improving our services;
  • managing customer relationships;
  • analysing Website usage; and
  • defending our legal rights.

Consent

Where required by law, we will ask for your consent before processing your Personal Data.

You may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

For special categories of personal data, such as genetic data and health data, additional requirements apply under Article 9 GDPR.

Article 7. DNA analysis provided by Superhlth

4Gold offers customers the possibility to purchase a DNA analysis provided by Superhlth.

The DNA Service is not a service performed by 4Gold itself.

Superhlth is responsible for the DNA analysis and the associated processing of genetic data and other health-related information, subject to the specific arrangements applicable to the service.

4Gold may receive or process limited information necessary to:

  • process the purchase of the DNA Service;
  • administer the customer relationship;
  • communicate with the customer regarding the order;
  • provide customer support; and
  • facilitate communication between the customer and Superhlth where necessary.

4Gold does not use your genetic data for its own independent purposes unless this is explicitly communicated to you and a valid legal basis exists.

For information about how Superhlth processes your DNA sample, genetic data, health data and DNA results, please consult Superhlth's Privacy Policy.

Article 8. Sharing Personal Data with third parties

4Gold applies the principle of data minimisation and only shares Personal Data with third parties where this is necessary for the purposes described in this Privacy Policy, where you have given consent, or where we are legally required to do so.

Depending on the services you use, Personal Data may be shared with:

Third party / category Purpose
Shopify Hosting and operation of the Webshop and processing orders
Shopify Payments Payment processing
Mollie Payment processing
Logistics and fulfilment partners Processing and delivering orders
Klaviyo E-mail communication and direct marketing
Google Analytics Website analytics, where applicable
IT and hosting providers Hosting, maintenance, security and technical support
Customer service providers Customer support
Superhlth Administration and provision of the DNA Service purchased through 4Gold
Laboratories and service providers Where necessary for services provided directly by 4Gold

This list may change as our business and service providers evolve.

Where a third party processes Personal Data on behalf of 4Gold, we will take appropriate measures to ensure that the processing is carried out in accordance with applicable data protection legislation.

Where a third party acts as an independent controller, that third party's own privacy policy may also apply.

Article 9. Direct marketing

4Gold may process your Personal Data for direct marketing purposes where this is permitted under applicable legislation.

This may include sending information about:

  • Products;
  • promotions;
  • discounts;
  • new products;
  • events;
  • campaigns; and
  • other 4Gold communications.

Where consent is required, we will obtain your consent before sending direct marketing communications.

You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism included in our communications or by contacting us at:

privacy@4gold.eu

You also have the right to object to processing of your Personal Data for direct marketing purposes, including profiling related to direct marketing. The Belgian Data Protection Authority confirms that data subjects have specific rights in relation to direct marketing.

Article 10. Transfers outside the European Economic Area

4Gold primarily uses service providers located within the European Economic Area.

However, some of our service providers may process Personal Data outside the European Economic Area ("EEA").

Where Personal Data is transferred outside the EEA, 4Gold will take the measures required by applicable data protection legislation, which may include:

  • an adequacy decision;
  • Standard Contractual Clauses;
  • appropriate supplementary measures; or
  • another lawful transfer mechanism recognised under the GDPR.

Article 11. How long do we retain your Personal Data?

We retain Personal Data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may vary depending on the type of data and the purpose of processing.

Customer and account information

Customer information may generally be retained for as long as you have an active customer relationship with 4Gold and thereafter for a period necessary to comply with legal obligations, resolve disputes or protect our legitimate interests.

Order and financial information

Order, invoice and financial information will be retained for the periods required by applicable accounting and tax legislation.

Subscription information

Information relating to your Gut Support subscription will generally be retained for as long as necessary to administer the subscription and thereafter for the periods required by law or necessary for legitimate business purposes.

Marketing information

Marketing preferences and related information will generally be retained until you withdraw your consent, object to the relevant processing, or the information is no longer necessary.

DNA information

4Gold does not itself retain your DNA sample or perform your DNA analysis.

The retention of genetic data, biological samples and DNA results by Superhlth is governed by Superhlth's applicable privacy policy and retention practices.

Technical information and cookies

Retention periods for technical information and cookies depend on the type of data and are described in our Cookie Policy where applicable.

Article 12. How do we protect your Personal Data?

4Gold takes appropriate technical and organisational measures to protect Personal Data against:

  • accidental or unlawful destruction;
  • loss;
  • alteration;
  • unauthorised disclosure;
  • unauthorised access; and
  • other unlawful forms of processing.

Depending on the circumstances, these measures may include:

  • encrypted communications;
  • access controls;
  • secure hosting environments;
  • authentication mechanisms;
  • restricted access to Personal Data;
  • processor agreements;
  • security monitoring; and
  • regular review of technical and organisational safeguards.

Despite these measures, no method of transmission or storage over the Internet can be guaranteed to be completely secure.

Article 13. Your rights

Subject to the conditions and limitations provided by applicable law, you have the following rights regarding your Personal Data:

  1. Right of access – you may request confirmation as to whether we process your Personal Data and, where applicable, obtain access to that Personal Data.
  2. Right to rectification – you may request correction of inaccurate or incomplete Personal Data.
  3. Right to erasure – you may request deletion of your Personal Data where the legal conditions for this right are met.
  4. Right to restriction – you may request restriction of processing in certain circumstances.
  5. Right to data portability – where applicable, you may request your Personal Data in a structured, commonly used and machine-readable format and request its transfer to another controller.
  6. Right to object – you may object to certain processing activities, including processing based on legitimate interests.
  7. Right to withdraw consent – where processing is based on your consent, you may withdraw that consent at any time.

These rights are subject to the conditions and exceptions provided by applicable data protection legislation.

You can exercise your rights by contacting:

Nutribam / 4Gold
Wechelsebaan 73A
2275 Lille
Belgium

E-mail: privacy@4gold.eu

We may request additional information to verify your identity before processing your request.

You should not send us a copy of your identity document unless specifically required. If identification is necessary, we will provide appropriate instructions.

Article 14. Complaints

If you believe that your Personal Data is being processed unlawfully, we encourage you to contact us first so that we can try to resolve the matter.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

In Belgium, the competent supervisory authority is the Belgian Data Protection Authority (GBA/APD). Its official website provides further information about your rights and how to lodge a complaint.

Belgian Data Protection Authority

Article 15. Third-party websites and services

Our Website may contain links to third-party websites, platforms or services.

If you follow such a link, the third party's own privacy policy and terms may apply.

4Gold is not responsible for the privacy practices of third-party websites or services that are not operated by 4Gold.

This is particularly relevant to the Superhlth DNA Service. Where you use Superhlth's services, Superhlth's own privacy policy and terms apply to the processing carried out by Superhlth.

Article 16. Disclosure required by law

4Gold may disclose Personal Data where this is required by law, regulation, court order or other legally binding request.

We may also disclose Personal Data where this is reasonably necessary to:

  • protect the rights and property of 4Gold;
  • protect the safety of our customers, employees or other persons;
  • investigate fraud or abuse;
  • enforce our contractual rights; or
  • establish, exercise or defend legal claims.

Article 17. Changes to this Privacy Policy

4Gold may update this Privacy Policy from time to time to reflect:

  • changes to our Products or Services;
  • changes to our Website;
  • changes to the way we process Personal Data;
  • changes to our service providers; or
  • changes in applicable legislation.

The most recent version will always be made available on the Website.

The date at the top of this Privacy Policy indicates when it was last updated.

Where required by applicable law, we will provide additional notice or obtain consent for material changes.

Article 18. Liability

4Gold takes reasonable measures to protect your Personal Data and to comply with applicable data protection legislation.

However, to the extent permitted by applicable law, 4Gold cannot be held responsible for unlawful processing by third parties where such third parties act as independent data controllers and are not processing Personal Data on behalf of 4Gold.

This includes third-party platforms or services that you choose to use independently, including services provided by Superhlth, where Superhlth acts as an independent controller.

Nothing in this Privacy Policy excludes or limits any liability that cannot legally be excluded or limited under applicable law.

Article 19. Applicable law and jurisdiction

This Privacy Policy is governed by Belgian law, without prejudice to mandatory provisions of applicable data protection legislation.

Any dispute concerning this Privacy Policy shall be submitted to the competent courts in accordance with applicable Belgian law and mandatory consumer protection rules.