PRIVACY AND SECURITY POLICY OF NUTRIGION CC (REG NO. 2007/240880/23)

1. Introduction

1.1 This Privacy and Security Policy explains how we protect and use personal information collected by us as a result of your use of the Services, whether via the Website and/or Mobile Applications. “Personal information” means any information that is recognized as such under South African Law and includes any information which identifies you or which, when linked to other information, can personally identify you.

1.2 When we refer to a “service provider”, we are referring to such third parties who perform on our behalf or assist us to render the Services including third party payment gateways. Such Service providers will only process your personal information strictly in accordance with our instructions and for the purpose for which such personal information has been disclosed. These service providers will always be under an obligation to protect your personal information on terms which provide the same or equivalent protection as set out herein

2. WHAT Information we collect

2.1 Please note that We only collect personal information which is reasonably necessary for the rendering of the Services to you

2.2 Registration information: name, email address and gender. This information is used to provide the Services to you including to deliver to you any administrative notices, alerts and communications relevant to your use of the Service

2.3 Billing information: We may require your 3rd Party Login ID, to let you withdraw earned tokens

2.4 Correspondence with us via the Website, the Mobile Applications, and SMS. We may use this information, including mobile numbers, the content of the message and the metadata pertaining to the message to communicate with you and to improve the Service;

2.5 Website connection information, statistics on page views, traffic to and from the Websites address and standard web log information,;

2.6 Authentication information for example, we may ask you to send us an ID or utility bill to verify your address, or to answer additional questions to help verify your identity. This information will only be used to verify your identity in the event we are called about to do so by law by any third party;

2.7 third-party account credentials including account numbers/account ID at financial institutions although this information is entered on the Website or via the Mobile Applications, we DO NOT SEE THIS INFORMATION SUCH INFORMATION IS TRANSFERRED IN ENCRYPTED FORM TO our Authorised Information Aggregation Service Provider ("AIASP") TO ENABLE our AIASP TO RETRIEVE ACCOUNT INFORMATION FROM YOUR NOMINATED FINANCIAL INSTITUTIONS AND SENDS THIS INFORMATION BACK TO US SO THAT WE CAN PROVIDE YOU WITH THE PROOF THAT THE TRANSACTION IS SUCCESSFUL. ANY INFORMATION THAT COMES BACK TO US EXCLUDES YOUR CREDIT CARD NUMBER.

3. HOW we use Personal Information.

Save as set out below, we will not use and/or disclose any personal information collected by us without your consent for any purposes other than the following –

3.1 to disclose to service providers who perform or assist us to perform the Services. Such Service providers will only process your personal information strictly in accordance with our instructions and for the purpose for which such personal information has been disclosed to them and where you have consented to such disclosure

3.2 for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;

3.3 we may merge your personal information with information received from other sources in order to improve our service offering

3.4 In addition, we may disclose personal information to law enforcement, other government officials, or other third parties as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us to legal liability

3.5 If we become involved in any merger, consolidation, or sale of our assets and this involves the sharing in any way of your personal information, we will ensure the confidentiality of such information and let you know before your personal information is transferred and becomes subject to a different privacy policy. Should you not wish for your personal information to be so transferred, you can notify of this and you may cancel the service

3.6 Cookies. Unless you have cookies disabled, we will store a cookie on your computer. A “cookie” is a text file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. Use cookies allow a Website to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. We may use cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our marketing campaigns; (d) monitor aggregate metrics such as total number of visitors, pages viewed, etc.

4. Third party Personal information

4.1 Third party personal information (being personal information collected by us from someone other than you) (“third party PPI”) is collected from – Facebook, Youtube(Google) and Payment Portals.

4.2 The types of the entity(ies) collecting Third Party personal information; Social media sites and Payment Portals.

4.3 What kind of Third Party personal information is collected, either through active or passive means; Facebook userId, email, and gender are actively collected. We will only capture your Paypal Id/Account number when the user withdraws funds. All other permissions are disabled, until the user enables the permission during website usage or on the settings page, where you can revoke any or all permissions.

4.4 How collected Third Party personal information is used and/or disclosed; Your userId is to create and maintain your presence on our site. Should you connect a video to our site, the Facebook owner of the video will be linked to the video, which will also be linked to the source link on Facebook/Youtube. Your birthdate is needed for your assessment while all other permissions are only needed if you want to connect social aspects and/or your own videos.

4.5 Collected Third Party PII is also shared withFacebook, Pay Pal and Google only to the extent that it is required by that Third Party in actioning consent already provided to those third parties when utilising those services.

4.6 Should you wish to be removed from search results containing Third Party PII, please follow the opt out procedure in 10

5. Correction And Updating Of Personal Information

5.1 Should you wish to correct or update inaccurate personal information and/or Delete personal information or withdraw consent for the use of your personal information, please email such request to nutrigion@gmail.com.

5.2 Once the inaccuracies have been corrected, we notify you by way of email ; and

5.3 You will be able to have access to your personal information as follows – Click on the settings tab and then on username. All information is updated to match live Facebook profile information. Only once the user logs in, if the page/username has changed our database will update. Email nutrigion@gmail.com for other account information. Information on any videos the user owns can be accessed directly through the user’s owned content, click on settings once an item you own is selected.

5.4 If any information collected by the Participant about an Individual is disputed by that Individual and is found to be inaccurate, incomplete, or cannot be verified, Participant shall promptly delete or modify that item of information, as appropriate, based on the results of the investigation.

5.5 We are entitled to refuse you access to your personal information and in such circumstances we will tell you why access was denied and contact information for further inquiries regarding the denial of access. where –

5.6 Such access would prejudice the confidentiality necessary to comply with regulatory requirements, or breach our confidential information or the confidential information of others;

5.7 The burden or cost of providing access would be disproportionate or the legitimate rights or interests of others would be violated.; or

5.8 The requested personal information is derived from public records or is Publicly Available Information and is not combined with non-public record or non-publicly available information.

6. Publicly Displayed Personal Information

6.1 You may post your personal information in an online forum, chat room, blog or other public forum. Should you wish to have your publicly displayed personal information removed, please contact us at nutrigion@gmail.com.

PLEASE BE AWARE THAT INFORMATION POSTED BY YOU IN ONLINE FORUMS, CHAT ROOMS, BLOGS, OR OTHER PUBLIC FORUM MAY BE DISPLAYED PUBLICLY

7. Security:

Our software transfers all your information using 2,048 Bit encryption assuring any communications between you, our server and external sources (Facebook, Youtube and Paypal) are private and secure. Through the use of 3rd party security systems we monitor our system live for Code Alterations, Malicious Code, Spam, Phishing, Malware, Website Attacks, SQL Injection and Active intrusion detection. Access to your data is protected against unauthorized access.

While we assure to keep upto date with all requirements set out by 3rd party sites, but do no control the sites themselves and therefore cannot be held responsible for their privacy and security arrangements of those sites.

No financial information is stored at any time.

8. Data Retention

Personal information collected by us will be will be kept by us for as long as you are an active user of the Service. We reserve the right to retain the information collected up to the date of your cancellation of the Service and thereafter. This data will always be maintained under the same security and privacy controls that are in place for other users of the service. Nutrigion can retain thereafter for 7 years.

9. Opt out

You are entitled to opt out of any disclosure of your personal information. Should you choose to do this, and should the opt out be in respect of personal information which is necessary to provide the Service, we may not be able to continue to provide the Services to you and in such circumstances, we will immediate notify of this. Should you still wish to opt out after such notification, we will be entitled to terminate the Services. Should you wish to opt out, please contact us at nutrigion@gmail.com

10. Email address and Password

Login to our website using your Facebook log in details, at no point will we gain access to your password. 11. Policy Modifications and Material Changes.

11.1 We may change this Privacy and Security Policy from time to time and we will post any changes on the Website.

11.2 We will notify you of any degradation in your rights or our obligation obligations regarding the collection, use, or disclosure of your personal information for an Individual before such changes are made

12. Comments and Questions. If you have any questions, comments or concerns about our Privacy and Security Policy, please contact us at nutrigion@gmail.com.

©2020 by Nutrigion. Founded 2007.