Privvacy Policy
Last Modified: July 19, 2021
Welcome to Kristen Willard, RDN’s (“Company,” “we,” or “us”) Privacy Policy.
We respect your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit www.bariatricmealprep.com (the “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and processes your personal data through your use of this Website, including any data you may provide through this Website when you sign up to our blog, purchase a product or service, or access the Website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
CONTROLLER
Kristen Willard, RDN is the controller and responsible for your personal data collected through the Website. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at: email.[HK1]
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Privacy Policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
Profile Data includes, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Financial Data
Financial Data includes bank account and payment card details. We do not collect any Financial Data about you. We conduct all online purchases through the following:
- Practice Better – All payments for nutrition consults are handled by Practice Better and we do not retain any of this information.
- Gumroad – All payments for ebooks are handled by Gumroad and we do not retain any of this information.
- Kajabi – All payments for courses and symposiums are handled by Kajabi and we do nto retian any of this information.
For information on how these third-parties handle your Financial Data please review their privacy policies.
Medical Data
Medical Data includes medical history, clinical data, surgeries, medications, treatment plans, allergies, laboratory results, radiological studies, immunization records, and other such information. We do not collect any Medical Data about you. All Medical Data is collected and handled by Practice Better. If you have questions about how your Medical Data is handled please review Practice Better’s privacy policy.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties that use cookies to collect information pertaining to you and share it with us for advertising purposes.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
| Type of data
| Lawful basis for processing including basis of legitimate interest |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
This Website uses Mediavine to manage all third-party advertising on the Website. If you do not wish to receive personalized adds you can set your browser to refuse these ads. If you have questions regarding how Mediavine collects and uses your data see their privacy policy at https://www.mediavine.com/privacy-policy/.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase
COOKIES
This Website utilizes industry standard analytics packages which gather limited information on visitors to our Website automatically and stores this anonymous information in server log files. This information may include IP addresses, browser type, basic IP information, referring pages, operating system used and date/time stamps. This information does not identify individual users; it is used only for site administration, as well as for analysis of website usage and trends.
Additionally, cookies may be used to provide easier and faster access to website features such as logins and/or repeat visits. Cookies are very small text files that are stored on personal computers for reference purposes. We do not store in cookies to any personally identifiable information in cookies.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You may have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above and you believe you have the right to do so, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
GLOSSARY
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External third parties means:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services.
[HK1]What email would you like people to contact you at?
[HK2]Is someone accesses your website from the EU then Mediavine should provide a pop-up where the user can opt-in to give consent. The GDPR requires express opt-in if a website allows data to be used or sold to a third-party.
[HK3]You should have some type of strategy in place in case you do have a security breach. This will not be inspected or challenged unless a security breach occurs.
[HK4]Most of these rights pertain to Californians. This is why I used the word “may.”
Since you are using Mediavine, if a user located in CA wants you to not store their data, then you must comply.
Mediavine Programmatic Advertising
The Website uses Mediavine to manage all third-party advertising on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie may collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from a third-party site, the URL of the linking page.
First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies/.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site.
The Website may collect IP addresses and location information to serve personalized ads and pass it to Mediavine. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit https://www.networkadvertising.org/managing/opt_out.asp. You may also visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/# to learn more information about interest-based advertising. You may download the AppChoices app at https://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
Mediavine partners with the following data processors:
- Pubmatic. You may find Pubmatic’s privacy policy through this link. The data collected on the Website may be transferred to Pubmatic and its demand partners for interest-based advertising. Statistical information and other non-cookie technologies (such as eTags and web or browser cache) may be used by third parties on this Website. Browser settings that block cookies may have no effect on these technologies, but you may clear your cache to delete such trackers. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected.
- Criteo. You may find Criteo’s privacy policy through this link. The data collected on the Website may be transferred to Criteo and its demand partners for interest-based advertising. Criteo may collect, access, and use non-identifying data to improve the Criteo Technology and other Criteo products, programs, and/or services. This non-identifying data may include on-site user behavior and user/page content data, URLs, statistics, or internal search queries. The non-identifying data are collected through the ad call and stored with a Criteo cookie for a maximum period of 13 months.
- Pulsepoint. You may find Pulsepoint’s privacy policy through this link.
- LiveRamp. You may find LiveRamp’s privacy policy through this link. When you use the Website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating system, with LiveRamp Inc, and its group companies (‘LiveRamp’). LiveRamp may use a cookie on your browser and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email, in-app, etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. To opt out of LiveRamp’s targeted advertising, please go here: https://liveramp.com/opt_out/
- RhythmOne. You may view RhythmOne’s privacy policy through this link. RhythmOne uses cookies and similar tracking technologies (such as mobile device identifiers and digital fingerprinting) to provide its services. RhythmOne may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the following webpage: https://www.networkadvertising.org/managing/opt_out.asp.
- District M. You may find District M’s privacy policy through this link.
- YieldMo. You may find YieldMo’s privacy policy through this link. If you want to opt out of receiving interest based ads from Yieldmo or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link.
- The Rubicon Project. You may find Rubicon’s privacy policy through this link. If you want to opt out of receiving interest based ads from Rubicon or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page.
- Amazon Publisher Services. You may find Amazon Publisher Services’ privacy policy through this link.
- AppNexus. You may find the AppNexus privacy policy through this link.
- OpenX. You may find OpenX’s privacy policy through this link.
- Verizon Media formerly known as Oath. You may find Verizon Media’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
- TripleLift. You may find TripleLift’s privacy policy through this link. To opt out of receiving interest-based advertising (including retargeting) from TripleLift’s services through the use of cookies in your current browser and for more information on what it means to opt-out, please go to www.triplelift.com/consumer-opt-out.
- Index Exchange. You may find Index Exchange’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
- Sovrn. You may find Sovrn’s privacy policy through this link.
- GumGum. You may find GumGum’s privacy policy through this link. GumGum may (i) use place and use cookies on end users’ browsers or use web beacons to collect information about end users who visit such Publisher Websites and (ii) link such collected end user information to other end user information provided by third parties in order to deliver targeted Advertisements to such end users.
- Digital Remedy. You may find Digital Remedy’s privacy policy through this link.
- MediaGrid. You may find MediaGrid’s privacy policy through this link. MediaGrid may collect and store information about end-user interactions with this website through cookies, advertising IDS, pixels and server-to-server connections. MediaGrid was receive the following information: the page an End-User has requested and the referring/exit pages; Timestamp information (i.e., the date and time the End-User has visited the page); IP address; mobile device identifier; device model; device operating system; browser type; carrier; gender; age; geolocation (including GPS coordinates); clickstream data; cookie information; first-party identifiers’; and hashed email addresses; demographic and inferred interest information; and post-conversion data (from both online and offline behaviour). Some of this data is gathered from this website and others is gathered from advertisers. MediaGrid uses this data to provide its services. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising or review their privacy policy for more information.
- RevContent – You may find RevContent’s privacy policy through this link. RevContent may collect information about your browser or device, including browser type, IP Address, device type, user agent string, and operating system. RevContent also collects information about the websites you visit through their services, such as date and time of access and specific pages accessed and the content and ads you click on. You may opt-out of any personalization track by opting-out of RevContent’s data collection.
- Centro, Inc. – You may find Centro’s privacy policy through this link. You may find opt-out information for Centro’s services through the privacy policy link.
- 33Across, Inc. – You may find 33Across’s privacy policy through this link. To opt-out of personalized advertising, please visit https://optout.networkadvertising.org/?c=1.
- Conversant. LLC – You may find Conversant’s privacy policy through this link. Conversant uses information that does not directly identify you, such as information about your browser type, time and date of visit, your browsing or transaction activity, the subject of advertisements clicked or scrolled over, and a unique identifier (such as a cookie string, or a unique advertising identifier provided by your mobile device) during your visits to this and other websites and apps in order to provide advertisements about goods and services likely to be of greater interest to you. Conversant may use technologies such as cookies and other tracking technologies to collect this information. To learn more about interest-based advertising, or to opt-out, you can visit www.youronlinechoices.eu or https://www.networkadvertising.org/.
