Privacy Policy

1. Privacy Policy Overview

Summary – Policy Overview

This Policy explains how we may Process your information. This Policy may be  amended or updated from time to time, so please check it regularly for updates. 

Gastro Girl, Inc., with its parents, affiliates and its subsidiaries (collectively, “Gastro  Girl”, “us”, “our” or “we”), owns, operates, or provides access to, several interactive  health, wellness, diet and fitness websites, mobile and connected applications, and other  online interactive features and services, including, but not limited to, emails, newsletters,  chat areas, forums, communities, sweepstakes and contests for consumers  (collectively “Services”). This Privacy Policy applies to all information collected about you  when you interact with the Services, regardless of how it is collected or stored, and  describes, among other things, the types of information collected about you when you  interact with the Services, how your information may be used, when your information may  be disclosed, how you can control the use and disclosure of your information, and how  your information is protected. 

Except as otherwise noted in this Privacy Policy, Gastro Girl is a data controller (as that  term is used under the EU General Data Protection Regulation (“GDPR”)), which means  that we decide how and why the information you provide to us is processed. Please contact  us privacy@gastrogirl.com. This Policy may be amended or updated from time to time to  reflect changes in our practices with respect to the Processing of your information, or  changes in applicable law. We encourage you to read this Policy carefully, and to regularly  check this page to review any changes we might make. 

This Privacy Policy covers information collected through the websites Gastro Girl and the related applications.


 

2. What Categories of Information We May Process

Summary – Categories of Information We May Process

We may Process: your personal details (e.g., your name); demographic data (e.g., your  age); your contact details (e.g., your address); records of your consents; purchase  details; details of your employer (where relevant); information about your interactions  with our content or advertising; and any views or opinions you provide to us. We may also Process information about you from your use of our Services (e.g., the  type of device you are using, the internet service provider, etc.), including your  interactions with content and advertising on the Services.

Personal Information” means information that is about any individual, or from which any  individual is directly or indirectly identifiable. 

Process”, “Processing” or “Processed” means anything that is done with any Personal  Information, whether or not by automated means, such as collection, recording,  organization, structuring, storage, adaptation or alteration, retrieval, consultation, use,  disclosure by transmission, dissemination or otherwise making available, alignment or  combination, restriction, erasure or destruction. 

We may Process the following categories of Personal Information about you: Personal details: your name; username or log in details; password; areas or topics  of interest; information provided in response to quizzes or surveys or to use certain  health-related programs, such as weight goals and caloric intake; and photograph (if  you or another user posts a photo on the Service). 

  • Demographic information: gender; age/date of birth; nationality; salutation; job  title, company information, education, work experience and other professional  information; and language preferences. 
  • Contact details: postal address; telephone and/or mobile number; email address;  and your public social media handles or profile(s). 
  • Consent records: records of any consents you may have given, together with the  date and time, means of consent and any related information (e.g., the subject  matter of the consent). 
  • Location information: location data that describes the precise geographic location  of your device (“Precise Location Data”). 
  • Purchase and payment details: records of purchases and prices; invoice records;  payment records; billing address; payment method; cardholder or accountholder  name; payment amount; and payment date. 
  • Employer details: where you interact with us in your capacity as an employee, the  contact information of your employer (including name, address, telephone number  and email address) to the extent relevant. 
  • Views and opinions: any views and opinions that you or other users choose to send  to us, or publicly post about us on social media platforms or in the Services,  including on forums. 

We also collect other kinds of information from you or other sources, which we refer to as  “Other Information” in this Policy, which may include but is not limited to: Information about your use of the Services, such as usage data and statistical  information, which may 

  • Browsing history including the websites or other services you visited before and  after interacting with the Services. 
  • Searches for and interactions with e-commerce opportunities, such as merchants  and offers contained in the Services. 
  • Non-precise information about the approximate physical location (for example, at  the city or zip code level) of a user’s computer or device derived from the IP address  of such computer or device (“GeoIP Data”).
  • Device identification (“ID”), which is a distinctive number associated with a  smartphone or similar handheld device, but is different than a hardware serial  number. 
  • Advertising ID, which is a unique, user-resettable identification number for  advertising associated with a device (e.g., iOS uses the Identifier for Advertising  (or “IDFA”) and Android uses Google Advertising ID). 
  • Internet Protocol (“IP”) address, which is a unique string of numbers automatically  assigned to your device whenever you access the Internet. 
  • Information collected through the use of cookies, eTags, Javascript, pixel tags,  device ID tracking, anonymous identifiers and other technologies, including  information collected using such methods and technologies about (i) your visits to,  and interaction and engagement with, the Services, content and ads on third party  websites, applications, platforms and other media channels (“Channels”), and (ii)  your interaction with emails including the content and ads therein (collectively, “Online Data”). 
  • Device type, settings and software used. 
  • Log files, which may include IP addresses, browser type, ISP referring/exit pages,  operating system, date/time stamps and/or clickstream data, including any clicks  on customized links. 
  • Web Beacons, which are electronic files that allow a website to count users who  have visited that page or to access certain cookies. 
  • Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are  a method for passing information from the user’s computer to a third-party website. Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5. Mobile analytics to understand the functionality of our mobile applications and  software on your phone. 

Under certain circumstances and depending on applicable law, some of this Other  Information may constitute Personal Information. Personal Information together with Other  Information is hereinafter referred to as “User Information”.


 

3. Sensitive Personal Information

Summary – Sensitive Personal Information

Where we need to Process your Sensitive Personal Information for a legitimate  purpose, we do so in accordance with applicable law. The Services are not intended  for use by children. 

To the extent that information we collect is health data or another special category of  personal data subject to GDPR, we ask for your explicit consent to process the data. We  obtain this consent separately when you take actions leading to our obtaining the data, for  example, when you sign up for a newsletter on our site or agree to allow us to track you. You can withdraw your consent at any time by unsubscribing from our newsletters as  set out in Section 6 or adjusting your preferences as set out in Section 15. Children. The Services are not intended for use by children, especially those under 13. No  one under the age of 13 should provide any Personal Information or use our public  discussion areas, forums or chats. Minors under the age of 18 are not permitted to make  purchases through the Services or obtaining coupons or codes from the Services to  purchase goods or services on third party websites. If, notwithstanding these prohibitions,  your children disclose information about themselves in our public discussion areas,  consequences may occur that are not intended for children (for example, they may receive  unsolicited messages from other parties). If it is discovered that we have collected  Personal Information from someone under 13, we will delete that information immediately.


 

4. How We Collect or Create Information

Summary – Collection and Creation of Information

We may collect or obtain User Information about you: directly from you (e.g., where  you contact us); in the course of our relationship with you (e.g., if you make a  purchase); when you make your Personal Information public (e.g., if you make a public  post about us on social media); when you download, install, or use any of our  Services; when you visit our Services; when you register to use any part of the  Services; or when you interact with any third party content or advertising on the  Services. We may also receive User Information about you from third parties (e.g.,  social network sites). We may also create User Information about you, such as records  of your interactions with us. Gastro Girl is not responsible for Personal Information  you volunteer about yourself in public areas of the Services. This Policy does not  cover the practices of third parties who may provide information about you to Gastro  Girl. 

Collection of User Information: We may collect User Information about you from the  following sources: 

  • Data you provide: We may obtain your Personal Information when you provide it to  us across our Services (e.g., where you sign up for emails, newsletters or SMS  messages; register for site membership or create a profile or account on any part of  the Services; enter a sweepstakes, contest, competition or prize draw; participate in  surveys and quizzes; perform search queries through the Services; contact us via  email, telephone or by any other means; make a purchase; etc.). 
  • Relationship data: We may collect or obtain your Personal Information in the  ordinary course of our relationship with you (e.g., if you purchase a service from us).
  • Data you make public: We may collect or obtain your Personal Information that you  clearly choose to make public, including via social media (e.g., we may collect  information from your social media profile(s) if you make a public post about us) or  through our chats, forums or communities on the Services.
  • Service data: We may collect or obtain your Personal Information when you visit,  download, use or register to use any part of our Service. 
  • Content and advertising information: If you choose to interact with any third-party content or advertising on the Services or Channels, we may receive User  Information about you from the relevant third party. 
  • Third party information: We may collect or obtain your Personal Information from  third parties who provide it to us. This may include offline channels such as through  telephone or direct mail efforts; from customers, vendors, suppliers, third parties,  commercially available or publicly available sources (e.g., data brokers, data  aggregators, public databases, etc.); third party affiliate network operators; referral  sources; and social network sites or services (e.g., Facebook, Twitter, LinkedIn,  etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter,  or Google+) to access the Services, create a membership or profile on any part of  the Services, access our content or forward our content to another person, platform  or service, we may also receive your username or email address for those third party  services or other information available about you or collected from you on those services. 

Please note that Gastro Girl is not responsible for the information you volunteer about  yourself in the discussions in certain public areas of the Services, such as forums, blogs,  wikis, chat rooms, private messages, message boards or other publicly accessible  interaction, or information that you choose to make public in your member profile or other  areas of the Services that allow users to upload or post content. We discourage users from  posting such Personal Information in this fashion. You can change your publicly available  information at any time via your profile page. To request removal of your Personal  Information from these areas, please contact us privacy@gastrogirl.com using. In some  cases, we may not be able to remove your Personal Information, in which case we will let  you know we are unable to do so and why. 

This Privacy Policy does not cover the practices of third parties, including those that may  disclose information to Gastro Girl. 

Creation of User Information. We may also create User Information about you, such as  records of your interactions with us and details of your purchase history, for internal  administrative purposes and analysis. We may also use User Information you have  provided to us with data obtained from third parties to enhance our records or enhance our  ability to provide products and services, such as appending additional information to your profile.


 

5. Purposes for Which We May Process Your Information

Summary – Purposes for Which We May Process Your Information

We may Process User Information for the following purposes: providing the Services to  you; communicating with you; providing advertising to you on the Services and  Channels; analyzing engagement with our audience; observing user engagement and  purchase activity across the Service and Channels; offering lead generation services;  marketing our services and offerings to current and prospective customers; managing  our IT systems; financial management; conducting surveys and quizzes; ensuring the  security of our systems; conducting investigations where necessary; compliance with  applicable law; and improving our Services. 

The purposes for which we may Process User Information, subject to applicable law,  include: 

  • Provision of the Services to You: providing the Services to you from Gastro Girl or  its partners including (i) offering of contests, as well as chat areas, forums and  communities, (ii) management of your account, and (iii) customer support and  relationship management. 
  • Offering and Improving the Services: operating and managing the Services for you;  providing personalized content to you; communicating and interacting with you via  the Services; identifying issues with the Services and planning improvements to or  creating new Services; and notifying you of changes to any of our Services. 
  • Identification: using information from third parties to verify information about you  in order to provide the Services (e.g. verify your mailing address to send you  requested products or services. 
  • Surveys and Quizzes: engaging with you for the purposes of obtaining your views on  our Services, as well as learning more about your interests, including your interest in  third parties and their offerings. 
  • Research: analyzing, benchmarking and conducting research based on User  Information and your interactions with the Services. 
  • Communications: communicating with you via any means (including via email,  telephone, text message, social media, post or in person) regarding content and  other information in which you may be interested, subject to ensuring that such  communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and  obtaining your prior, opt-in consent where required. We may provide direct  marketing to you as set out in Section 6 below.
  • Advertising: providing advertising based on your interests and interactions with the  Services and Channels, including using User Information to serve you  advertisements on the Services and Channels, as well as licensing segments of  User Information to third parties. For further information, please see Section 7  below. 
  • Audience Engagement: identification and development of audience engagement,  advertising and promotional strategies on various platforms and channels, both  within the Service and on Channels. 
  • User Engagement and Purchases: tracking purchase traffic and activity across the  Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being  made.
  • Commerce Offerings: using cookies to track your browsing history and the amount  of money spent at a particular third-party merchant’s site to offer coupons and  other offers that are relevant to your shopping experience. 
  • Lead Generation: producing customer leads that are shared with third party  advertisers through marketing campaigns, including but not limited to email  marketing and site placements. 
  • Marketing to Customers: We may market to current and prospective customers  and their employees who have indicated an interest in doing business with, or have  previously conducted business with, Gastro Girl in order to further generate and  promote our business. Such efforts include sending marketing emails or  conducting phone calls to drive the purchase of advertising, marketing our lead  generation, job boards, and other business services offered by Gastro Girl. 
  • IT Administration: administration of Gastro Girl’s information technology systems;  network and device administration; network and device security; implementing data  security and information systems policies; compliance audits in relation to internal  policies; identification and mitigation of fraudulent activity; and compliance with  legal requirements. 
  • Security: electronic security measures (including monitoring of login records and  access details) to help mitigate the risk of and provide the ability to identify and  rectify a security incident. 
  • Financial Management: general business and financial management purposes,  including: economic, financial and administrative management; planning and  reporting; personnel development; sales; accounting; finance; corporate audit; and  compliance with legal requirements 
  • Investigations: detecting, investigating and preventing breaches of policy, and  criminal offences, in accordance with applicable law.
  • Legal Proceedings: establishing, exercising and defending legal rights. Legal Compliance: Subject to applicable law, we reserve the right to release  information concerning any user of Services when we have grounds to believe that  the user is in violation of our Terms of Use or other published guidelines or has  engaged in (or we have grounds to believe is engaging in) any illegal activity, and to  release information in response to court and governmental orders, other requests  from government entities, civil subpoenas, discovery requests and otherwise as  required by law or regulatory obligations. We also may release information about  users when we believe in good faith that such release is in the interest of protecting  the rights, property, safety or security of Gastro Girl, any of our users or the public,  or to respond to an emergency.

 

6. Direct Marketing

Summary – Direct Marketing

We may Process your User Information to contact you with information regarding  services that may be of interest to you. You may unsubscribe for free at any time. 

We may Process your User Information to contact you via email, telephone, direct mail, or  other methods of communication to provide you with information regarding the Services  that may be of interest to you. We may send information to you regarding the Services,  upcoming promotions and other information that may be of interest to you, using the  contact details that you have provided to us and always in compliance with applicable law. You may unsubscribe from our newsletter lists at any time by following the unsubscribe  instructions included in every email we send. We will not send you any emails from a list  you have selected to be unsubscribed from, but we may continue to contact you to the  extent necessary for the purposes of any other Services you have requested or for  additional emails you have signed up for.


 

7. Cookies, Similar Technologies and Online Behavioral Advertising

Summary – Cookies, Similar Technologies and Online Behavioral Advertising

We may Process your User Information by placing or reading Cookies and similar  technologies on the Services and Channels. Certain tracking technologies enable us  to assign a unique identifier to you, and relate information about your use of the  Services to Other Information about you, including your User Information for the  purposes of learning more about you so we can provide you with relevant content and  advertising. We and our partners also use these technologies to analyze trends;  administer the Services; collect and store information such as user settings,  anonymous browser identifiers and video viewing history; supplement to our server  logs and other methods of traffic and response measurement; track users’ location  and movements around the Services; gather demographic information about our user  base; and to improve our understanding of traffic on the Services, visitor behavior, and  responses to promotional campaigns. 

Gastro Girl and/or certain third parties may collect information about you for online  behavioral advertising purposes in order for you to receive relevant interest-based  advertising on the Services and on other websites, platforms and media channels. We  use Online Data as well as other User Information to send you online behavioral ads.  Online Data is aggregated with the Other Information and data we collect and/or  similar data collected by partners to create groups of users and certain general interest categories or segments that we have inferred. We use this information to get a  more accurate picture of audience interests in order to serve ads we believe are more  relevant to your interests. 

Gastro Girl and its partners may use cookies and other tracking technologies to analyze  trends, administer Services, track users’ movements around the Services and on third  party sites, devices and applications, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you  choose to disable cookies, it may limit your use of certain features or functions on the  Services. 

Tracking technologies on the Services may be deployed by Gastro Girl and/or by our service  providers or partners. Certain tracking technologies enable us to assign a unique identifier  to you, and relate information about your use of the Services to other information about  you, including your User Information. We may match information collected from you  through different means or at different times and use such information along with offline  and online information obtained from other sources (including from third parties),  including, but not limited to, demographic information and updated contact information,  for the purposes of learning more about you so we can provide you with relevant content  and advertising. 

When you receive email messages or newsletters from us, we may use web beacons,  customized links, clear GIFs or similar technologies to determine whether the email has  been opened and which links you click in order to provide you with more focused email  communications or other information, and/or to aggregate that information with other data  we collect to use for some or all of the purposes outlined in this Privacy Policy. We and our partners (including but not limited to e-commerce partners, affiliates, and  analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses,  Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends;  administer the Services; collect and store information such as user settings, anonymous  browser identifiers and video viewing history; supplement our server logs and other  methods of traffic and response measurement; track users’ location and movements  around the Services; gather demographic information about our user base; and to improve  our understanding of traffic on the Services, visitor behavior, and responses to promotional  campaigns. We may receive reports based on the use of these technologies by these third  party companies on an individual and aggregated basis. For example, we may connect  information about your IP address to known corporate or User Information and use the  associated information related to aggregate content preferences to assist in our efforts to  market services to you or the originating corporation(s). Various browsers may offer their  own management tools for removing Local Storage.  

We may use mobile analytics software to collect data and to better understand the  functionality of our mobile software, devices and applications on your phone and other  devices. This software may record information such as how often you use the application,  the events that occur within the application, aggregated usage, performance data, and  where the application was downloaded from. We may link this information to User  Information. 

Gastro Girl and/or certain third parties may collect information about you for online  behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is  also referred to as interest-based advertising. 

Gastro Girl displays ads on both the Services and on the Channels. We may use Online  Data as well as other User Information to send you OBA. For example, if you read an article  about a particular subject on the Services, we may use cookies from a vendor to later serve  you an advertisement for a particular product or service related to the viewed article. These  third-party vendors may connect information about pages you visit on the Services with  information about pages you visit on other Channels and show you advertising based on  this combined information. These advertisements may appear when you are visiting a  different section of the Services or on another Channel. Likewise, third party vendors may  serve you advertisements when you visit the Services based on your interaction with the  Services and other Channels. 

Online Data is aggregated with the Other Information and data we collect as described in  this Privacy Policy and/or similar data collected by partners to create groups of users and  certain general-interest categories or segments that we have inferred based on (a)  demographic or interest data and GeoIP Data, (b) the pages you view and links you click  when viewing an email or using the Services and those of our partners, and/or (c) the  search terms you enter when using certain search services. We use this information to get  a more accurate picture of audience interests in order to serve ads we believe are more  relevant to your interests. We store page views, clicks, and search terms used for ad  personalization, targeting separately from your Personal Information. We may share de identified data segments with third parties, and where we do, we implement technical  measures and contractual requirements to prevent identification.


 

8. What is the Lawful Basis for Processing Personal Information

Summary – Lawful Basis for Processing User Information

We may Process your User Information where: you have given your consent; the  Processing is necessary for a contract between you and us; the Processing is required  by applicable law; the Processing is necessary to protect the vital interests of any  individual; or where we have a valid legitimate interest in the Processing. 

In Processing your User Information in connection with the purposes set out in this Policy,  we may rely on one or more of the following legal bases, depending on the circumstances:

  • Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to  Processing that is entirely voluntary – it is not used for Processing that is necessary  or obligatory in any way); 
  • Contractual necessity: We may Process your User Information where the  Processing is necessary in connection with any contract that you may enter into  with us;
  • Compliance with applicable law: We may Process your User Information where  the Processing is required by applicable law; 
  • Vital interests: We may Process your User Information where the Processing is  necessary to protect the vital interests of any individual; or 
  • Legitimate interests: We may Process your User Information where we have a  legitimate interest in carrying out the Processing for the purpose of managing,  operating or promoting our business, and that legitimate interest is not overridden  by your interests, fundamental rights, or freedoms. 

 

9. What Information We Disclose to Third Parties

Summary – Disclosure of User Information to Third Parties

We may disclose your User Information to legal and regulatory authorities; our  external advisors; parties who Process User Information on our behalf (“Processors”);  any party as necessary in connection with legal proceedings; any party as necessary  for investigating, detecting or preventing criminal offences; any purchaser of our  business; and any third-party providers of advertising, plugins or content used on the Services. 

We may disclose your User Information to other entities within the Company group, for  legitimate business purposes (including operating the Services, and providing services to  you), in accordance with applicable law. In addition, we may disclose your User Information to: 

  • legal and regulatory authorities, upon request, or for the purposes of reporting any  actual or suspected breach of applicable law or regulation; 
  • outside professional advisors (such as accountants, auditors, or lawyers), subject  to binding contractual obligations of confidentiality; 
  • third-party Processors (such as analytic providers; data centers; etc.), located  anywhere in the world, subject to the requirements noted below in this Section 9; any relevant party, law enforcement agency or court, to the extent necessary for the  establishment, exercise or defense of legal rights; 
  • any relevant party for the purposes of prevention, investigation, detection or  prosecution of criminal offences or the execution of criminal penalties, including  safeguarding against and the prevention of threats to public security; 
  • any relevant third-party acquirer(s), in the event that we sell or transfer all or any  relevant portion of our business or assets (including in the event of a reorganization,  dissolution or liquidation); 
  • any relevant third-party provider, where our Services use third party advertising,  plugins or content. If you choose to interact with any such advertising, plugins or  content, information about your activities on the Services and Channels to provide  you targeted advertising based upon your interests may be shared with the relevant  third-party provider. If you click or tap on or otherwise interact with an  advertisement, the advertiser may assume that you meet its target criteria;
  • any sponsors of contests, competitions, sweepstakes and prize draws, or content  offerings, the registration data for such events is to be used by us as part of User  Information, and may be shared with the sponsor and others, subject to this Policy  and the sponsor’s privacy policy. We may also share your information with third  party vendors involved in the administration of such events. For contests,  competitions, sweepstakes and prize draws, please read the official rules or terms  and conditions carefully before you submit your information; and 
  • to third parties whose practices are not covered by this Privacy Policy (e.g., third  party providers of goods and services, marketing and advertising companies and  agencies, content publishers and retailers). Under applicable law, we may share  Other Information with other parties who already possess your Personal Information  in order to enhance their records about you or enhance their ability to provide  products and services. 

For some of our Services, we may make some information, such as the name of our users,  their mailing address, phone number, email address—and in certain circumstances their  employer’s name, company size and other industry data—available on a rental or other  basis (e.g., sale) to third party providers of goods and services, for example, when such  information is provided in connection with certain content available on our  websites. Depending on where you reside, when you register for certain Services, we may  share the Personal Information you provide with certain advertisers and sponsors. Some of the Services may include websites that Gastro Girl operates on behalf of third  parties (“Licensors”). Where applicable, we may share some or all of your Personal  Information with the Licensor; however, this privacy policy does not cover the user of your  Personal Information by a Licensor. The privacy practices of Gastro Girl’s Licensors may  differ from this policy and we encourage you to contact those third parties directly if you  have questions regarding their use of your Personal Information. When you use a co branded service (a service operated with a partner of Gastro Girl), or register or otherwise  provide information on a co-branded site, where applicable, we may pass the collected  information back to that partner, which may include third party service providers whose  services are embedded into and/or appear within the Services. 

With respect to surveys and quizzes, in the event that responses are publicly disclosed,  users will be notified at the time they take the survey or quiz. Otherwise we will disclose  only aggregate information regarding its users’ responses in surveys or quizzes to other participants in the survey. Where surveys or quizzes allow users to submit written  comments, and where Gastro Girl advises users of the possibility of such disclosure at the  time they take the survey or quiz, Gastro Girl reserves the right to disclose any information  provided by users, provided that no User Information identifying a specific user is  disclosed. 

Gastro Girl and some of our advertisers may use third party advertising service companies  to serve advertisements, for OBA or otherwise, and perform related services when you  interact with the Services. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email  advertisements and to create a record of interaction with our content that they use in  conjunction with their advertising which appears on other sites or applications, or for  reporting website traffic, app use, statistics, advertisement data and/or other activities on  the Services. We also engage third party providers to assist with the segmentation of this data. 

We may also sell or transfer Online Data to certain third parties such as advertisers who  will use this data to serve ads that they believe are relevant to your interests, and who agree  to maintain the confidentiality of this information. Some of these third parties may  combine the Online Data with their own data about you to form a more detailed picture. We may engage third party providers to assist with the collection, storage and  segmentation of Online Data and the providers are required to maintain the confidentiality  of this information. These third-party providers may collect User Information from our  Services for their own purposes, including but not limited to monitoring fraud around the web. 

We may also engage third parties for the purpose of recognizing our users and delivering  interest-based content and advertisements to them. We may share your User Information  with our partners such as your name, postal address, email, or other identifier. Our  partners may also: (i) collect information directly from your device, such as your IP address,  device ID, advertising ID, and information about your browser or operating system; (ii)  combine User Information about you received from Gastro Girl with information about you  from other sites or services; and (iii) place or recognize a unique cookie on your browser. If we engage a third-party Processor to Process your User Information, the Processor will be  subject to binding contractual obligations to: (i) only Process the User Information in  accordance with our prior written instructions; and (ii) use measures to protect the  confidentiality and security of the User Information; together with any additional  requirements under applicable law. 

The Services contain links to other sites or partners whose information practices may be  different from ours. You should consult the privacy policy of these third parties to learn how  your privacy is protected.


 

10. Data Security

Summary – Data Security

We implement appropriate technical and organizational security measures to protect  your User Information. Please ensure that any Personal Information that you send to  us is sent securely. 

We have implemented appropriate technical and organizational security measures  designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or  unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a  non-human readable format to provide protection. However, we cannot guarantee there  will not be a breach, and we are not responsible for any breach of security or for the actions  of any third parties. 

Because the internet is an open system, the transmission of information via the internet is  not completely secure. Although we will implement reasonable measures to protect your  information, we cannot guarantee the security of your data transmitted to us using the  internet. Any such transmission is at your own risk and you are responsible for ensuring  that any Personal Information that you send to us are sent securely.


 

11. Data Accuracy

Summary – Data Accuracy

We take every reasonable step to ensure that your User Information is kept accurate  and up-to-date and are erased or rectified if we become aware of inaccuracies. 

We take every reasonable step to ensure that your User Information that we Process is  accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.


 

12. Data Minimization

Summary – Data Minimization

We take every reasonable step to limit the volume of your User Information that we  Process to what is necessary. 

We take every reasonable step to ensure that your User Information that we Process is  limited to the User Information reasonably necessary in connection with the purposes set  out in this Policy or as required to provide you services or access to the Services.


 

13. Data Retention

Summary – Data Retention

We take every reasonable step to ensure that your User Information is only retained  for as long as they are needed.

We take every reasonable step to ensure that your User Information is only Processed for  the minimum period necessary for the purposes set out in this Policy. The criteria for  determining the duration for which we will keep your User Information are as follows: we  will retain copies of your User Information in a form that permits identification only for as  long as is necessary in connection with the purposes set out in this Policy, unless  applicable law requires a longer retention period. Unless there is a specific legal  requirement for us to keep the information, we plan to retain it for no longer than is  necessary to fulfill a legitimate business need. 


 

14. Your Rights With Respect to Your Personal Information

Many privacy regulations afford consumers a number of specific rights. If you are a resident  of the EU (under GDPR), UK (under the UK GDPR), Brazil (under the LGPD), several U.S.  States, including California (CCPA), Virginia (under VCDPA), Colorado (under the CPA), and  Connecticut (under the CTDPA), or another jurisdiction with similar privacy requirements,  you have certain rights which may include those listed below. 

Your rights: 

  • Right to Withdraw Consent: Where you are requested to consent to the processing  of your personal information, you have the right to withdraw your consent at any  time. 
  • Right to Know: You have a right to know what personal information we collect,  process, and share or sell. This policy is meant to provide transparency with regard  to your data. If you have additional questions, you can email us at privacy@gastrogirl.com
  • Right of Access: You can request a copy of the personal information we have  collected about you from us. 
  • Right to Delete/Erase: You can request us to delete all the information we have  collected about you. It is important to note that by exercising your right to deletion  you may lose access to your account and any purchases, points or features  associated with it. If you wish to cancel your account or request that we no longer  use some or all of your information to provide you services, Contact Us
  • Right to Request Rectification: If you find that any of your information that we are  processing is inaccurate, you can contact us to have your information corrected. In  response, we will cancel or remove your information but may retain and use copies  of your information as necessary to comply with our legal obligations, resolve  disputes, and enforce our agreements. For certain requests, we may require additional information. 
  • (California) Right to Opt-out of the Sale or Sharing for Targeted Ads: Under some  circumstances we may sell or share the personal data you provide to us to provide  ads to you that align with your interests. If you would prefer not to have your data  sold or shared, you can opt-out of selling or sharing by submitting a request by  emailing privacy@gastrogirl.com. We may ask for additional information to verify  your request.
  • Right to Object to the Processing: You can object to our processing of your  personal information by emailing privacy@gastrogirl.com, under certain  circumstances. By objecting to processing, you may not be able to access some or  all of our services. This right is limited to personal data processed for commercial  purposes. 
  • Right to Object to the Use of Sensitive Personal Information: You have the right to  object to our use of your sensitive personal information. Sensitive personal  information is information about your health, race, religion, sexual orientation,  gender identity, political opinions or philosophical beliefs. You should always be  mindful about the personal information you share online, especially when it is  sensitive in nature. 
  • Right to Object to Automated Processing: You have a right to object to the  processing of your data for the purposes of automated decision making about you.
  • Right to not be Discriminated Against: You have a right to not be discriminated  against for exercising your rights. 
  • Right to Complain (EU,UK, Switzerland): Should you wish to raise a complaint  about the collection or use of your information, you have the right to do so without  prejudice to any other rights you may have. You may lodge a complaint with your  local data protection authority. 
  • Right to an Authorized Agent (CA): If you would like to make a request on behalf of  a California consumer who is a current or former customer, please provide an email  from the email address we have on file for the customer authorizing the request. You  may also make a request under the California Consumer Privacy Act on behalf of a  California consumer if you provide (1) a signed, written permission from the  consumer to act on your behalf, and the consumer verifies their own identity directly  with us; or (2) proof that the consumer has provided you with power of attorney  pursuant to Probate Code sections 4000 to 4465. We may deny a request from an  agent that does not submit proof that they have been authorized by the consumer to act on their behalf. 

In order to make privacy requests please visit our and fill out the form. You can also email  us at privacy@gastrogirl.com. Our contact information can be found in the “Contact  Details” section below. 

You may be required to verify your identity before we can give effect to these rights. If you  are making a request on behalf of a user, we require a signed authorization letter from the  consumer.


 

15. What Can I Do to Control My Information?

Summary – What Can I Do to Control My Information?

You can directly take steps to change your preferences for newsletters and online  behavioral advertising as outlined in this section. 

If you are an EU resident, you may have certain rights including: the right not to provide  your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or  restriction of Processing, of your Personal Information; the right to object to the  Processing of your Personal Information; the right to have your Personal Information  transferred to another controller; the right to withdraw consent; and the right to lodge  complaints with supervisory authorities. We may require proof of or need to verify  your identity before we can give effect to these rights. 

You may directly take steps to change your preferences as follows: 

Access to Your Personal Information. Upon request Gastro Girl will provide you with  information about whether we hold any of your personal information. You may access,  correct, or request deletion of your personal information by logging into your account or  contacting us through privacy@gastrogirl.com. We will respond to your request within a  reasonable timeframe. 

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe from a newsletter  or other email list at any time by following the instructions at the end of the newsletters or  emails you receive. Please allow five to ten business days for changes to take effect. On  some Services, member service-related communications are an integral part of such  Services to which you subscribe and you may continue to receive emails as part of that  particular portion of the Services unless you cancel your account, even if you opt out of the  newsletters or email list. If you have provided more than one email address to us, you may  continue to be contacted unless you request to unsubscribe each email address you have  provided. 

Push Notifications. We send you push notifications from time-to-time in order to update  you about any events or promotions that we may be running. If you no longer wish to  receive these types of communications, you may turn them off at the device level. To  ensure you receive proper notifications, we will need to collect certain information about  your device such as operating system and user identification information. Location Based Services. You may opt-out of having your Precise Location Data collected  by Gastro Girl at any time by editing the appropriate setting on your mobile device (which is  usually located in the Settings area of your device). 

When you use our website, we share information that we collect from you, such as your  email (in hashed form), IP address, or information about your browser or operating system,  with our identity partners/service providers. These partners return an online identification  code that we may store in our first-party cookie for our use in online, in-app, and cross channel advertising, and it may be shared with advertising companies to enable interest based and targeted advertising. To opt-out of this use, please click here

Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or  purge cookies from your browser by adjusting your web browser preferences. However, if  you “turn off,” purge, or disable cookies or pixel tags, although you may still use the 

Services, you may not be able to use all of the features, functions, or services available on  the Services. 

California Residents. In accordance with the California Online Privacy Protection Act, we  may collect Personal Information about your online activities when you use the Services.  While we give our users many avenues to opt out of providing Personal Information, we do  not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil  Code Section 1798.83, permits our users who are California residents to periodically  request and obtain certain information about any Personal Information disclosed to third  parties for direct marketing purposes. If you are a California resident and wish to make  such a request or if you wish for us to refrain from gathering your Personal Information,  please submit your request in writing to the contact details set out in Section 17 below. EU Residents. GDPR provides certain rights for EU residents. You may decline to share  certain information with us, in which case we may not be able to provide some of the  features and functionality of the Services. These rights include, in accordance with  applicable law, the right to object to or request the restriction of processing of your  information, and to request access to, rectification, erasure and portability of your own  information. Where we process your information on the basis of your consent, you have the  right to withdraw that consent (noting that such withdrawal does not affect the lawfulness  of any Processing performed prior to the date on which we receive notice of such  withdrawal, and does not prevent the Processing of your Personal Information in reliance  upon any other available legal bases). Requests should be submitted by contacting us by  email to privacy@gastrogirl.com.  

You may access, correct, or request deletion of your personal information by logging into  your account or emailing us at privacy@gastrogirl.com, regardless of your citizenship or  location.


 

16. Terms of Use

Summary – Terms of Use

For more information concerning your use of the Gastro Girl website and application, please see our Terms of Use

For more information concerning your use of the Gastro Girl website and the Gastro Girl,  please consult the Gastro Girl Terms of Use, which is incorporated by reference into this Privacy Policy. We recommend that you review the Terms of Use regularly, in order to  review any changes we might make from time to time.


 

17. Contact Details

Summary – Contact Details

You may contact us at the addresses set out below or by emailing privacy@gastrogirl.com

Gastro Girl
Attention: Legal Department
8 The Green, #8109
Dover, DE 19901 

If you have any comments, questions or concerns about any of the information in this  Policy, or any other issues relating to the Processing of User Information carried out by us,  or on our behalf, please contact: 

Gastro Girl
Attention: Legal Department
8 The Green, #8109
Dover, DE 19901 

privacy@gastrogirl.com

If you have an unresolved concern regarding your privacy or our use of data that we have  not addressed satisfactorily, please contact our U.S.-based third party dispute resolution  provider (free of charge) by clicking here


 

18. How this Privacy Policy May Change

We may change this Privacy Policy from time to time, and all changes will be effective at the  time we post them. If we believe there is a significant change to this Privacy Policy or our  data collection and use practices, we will indicate on our websites that our Privacy Policy  has changed prior to the change becoming effective. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services  shall be deemed your acceptance of the Privacy Policy. 

We urge you to come back to this web page and review this Privacy Policy regularly so  that you remain aware of the terms and conditions that apply to you.

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