Data Protection Policy | KetoCycle.Diet

Privacy policy

In this privacy policy, we, Keto Diets UAB, company code 305493532, registration address Aludariu St. 3., Vilnius, Lithuania, office address Aludariu St. 3., Vilnius, Lithuania (“Company”, “we”, “us” or “our”), explain how we handle your personal data when you visit our website, use our mobile apps, contact us through our official social media pages or email, and/or use our services.

Please note that in case you purchase physical goods while using our services, Max Nutrition UAB, company code 305420438, with registered office at Lvivo St. 37-101, Vilnius, Lithuania, office address Antakalnio 17, Vilnius, Lithuania is responsible for data processing with regard to this particular service. In such cases, “Company”, “we”, “us” or “our” shall refer to Max Nutrition UAB. In case you have any privacy related inquiries or requests associated to physical goods, you may contact us at the following email: [email protected].

In this notice you will find the answers to the following:

how we use your data;
when we may provide your data to third parties;
how long we store your data;
what is our marketing policy;
what rights related to personal data you possess;
how we use cookies;
other issues that you should take into account.

In case of any inquiries or if you would like to exercise any of your rights stipulated in this notice, you may submit such inquiries and requests by means provided in the Contacts section.

You may also contact Data Protection Officer of the Company regarding all privacy related issues at the following email: [email protected].

All the definitions used in this privacy policy have the same meaning as prescribed in Company’s General Terms and Conditions unless expressly stipulated otherwise in this privacy policy. This privacy policy forms an integral part of Company’s General Terms and Conditions.

In the event this privacy policy is translated into other languages and if there are differences between the English version and such translation, the English version shall prevail, unless otherwise provided.

How do we use your personal data?
1. This Section provides the following information:
  1. categories of personal data that we process;
  2. in case of the personal data that we did not obtain directly from you, the source and specific categories of that data;
  3. the purposes for which we may process your personal data; and
  4. the legal bases of the processing.
2. We process your account data (“account data”). The account data may include your name and email address, phone number, and other data that you provide while registering as well as your purchase history. We obtain such data directly from you. We process account data for the purposes of operating our website, providing our services, ensuring the security of our website and services, and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such contract, as well as our legitimate interest, namely monitoring and improving our website and services.
3. We process information relating to provision of services by us to you (“service data”). The service data may include your contact details (such as your email address), bank account and transaction details, as well as other information that you provide to us while filling out relevant questionnaires (such may include sensitive personal data, including the data related to your health; this type of data will be required only if it is necessary for the provision of the relevant service). The service data is processed with the purpose of providing services as well as keeping proper records of relevant transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, as well as our legitimate interests, namely the proper administration of our website and business. In case of sensitive personal data, including the data related to your health, the legal basis for processing is your explicit consent.
4. We may process information that you provide to us for the purpose of subscribing to our email messages and newsletters (“messaging data”). The messaging data is processed to send you relevant messages and newsletters. The legal basis for this processing is your consent. Also, if we have already sold goods or provided services to you via our website and/or apps, and you do not object, we may also process messaging data on the basis of our legitimate interest, namely for the purpose of maintaining and improving customer relations.
5. We may process information relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data is processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, ensuring uniform and high-quality consultation practice, and for investigating disputes between you and our employees.
6. We may process information related to your use of our website and/or apps, as well as information about the device (“device data”) that you're using when you're browsing our website or use our apps. Device data may include IP address, geographical location, browser type and version, operating system, device type, screen resolution, and (in case you agree to share such) your location data, information on the motion activity and use of our website and apps (i.e. referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use). We obtain such data through the use of cookies and similar technologies. Device data is processed to enhance the apps and the website as well as to set default options. We also use such data to get a better understanding of how you use our website and services as well as for securing both the website and the apps. The legal basis for this processing is our legitimate interest, namely the proper management of our website, apps and business.
7. We may process any of your personal data identified in this notice where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
8. We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
9. In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
10. Should the purpose or legal basis of data processing activities indicated in this paragraph change, we will inform you and, if the consent was the legal basis for data processing, we will re-obtain your consent.
11. Sometimes we may aggregate, anonymise or de-identify your personal data in such a way so that it cannot reasonably be used to identify you. Such data no longer constitutes personal data. We may use such data without restriction in any way allowed by law, including but not limited to sharing such data with our partners or research institutions, sharing in articles, blog posts and scientific publications, aggregating statistics about certain activities or symptoms from the data collected to help identify patterns across users and evaluate or modify our services.
12. We are following the principle of data minimisation: the personal data processed is adequate, relevant and limited exclusively to what is necessary in relation to the purposes for which it is processed.
13. Personal data is stored either on the servers of the Company or of our contractors, who are bound by specific contractual clauses regarding the processing of personal data as well as by the confidentiality obligations.
14. We are using a number of technical and organisational means to protect your personal data. Organisational security measures include: restricting access solely to authorised persons with a legitimate need to access personal data; signing confidentiality agreements; arranging trainings; creating and implementing relevant policies and procedures. Technical measures include: appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access; implementing access control and authentication tools; ensuring physical security; other measures.
When do we provide your data to others?
1. We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice. Such may include internal administration purposes as well as provision/sharing of IT, payment or marketing services or data centres in the group.
2. Depending on the payment method chosen by you, your personal data may be disclosed to and processed by our group company KARMA PROCESSING INCORPORATED, company code 7138602, registered address 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, office address 1000 West Street, Suite 1200, Wilmington, Delaware, 1980, email: [email protected] insofar as reasonably necessary for the purposes of collecting, processing, and administrating payments for the services.
3. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. We may disclose your personal data to our anti-fraud, risks and compliance providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.
5. We may disclose your personal data to our payment service providers. We will share service data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds, and dealing with complaints and queries relating to such payments and transfers.
6. In order to offer you Klarna’s payment methods, we might in the checkout phase pass your personal data in the form of contact and order details to Klarna so that Klarna can assess whether you qualify for their payment methods and so that they can tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.
7. We may disclose your personal data to other service providers insofar as it is reasonably necessary to provide specific services (including providers of servers and maintenance thereof, email service providers, service providers used for data analysis or marketing, call centres, customer satisfaction surveys or market research). We take all the necessary measures to ensure that such subcontractors implement proper organisational and technical measures required for security and privacy of your personal data.
8. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. Persons indicated in this Section may be established outside the Republic of Lithuania, European Union and European Economic Area. In case we transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy remains properly secured, including, where appropriate, signing standard contractual clauses for transfer of data. To find out more information regarding appropriate safeguards, you may contact us via email: [email protected].
How long do we store your data?
1. Your personal data that we process for any particular purpose shall not be kept for longer than is necessary for that purpose. In any case, it shall be kept for no longer than:
  1. account data will be retained for no longer than 5 (five) years following your last update on the account;
  2. service data will be retained for no longer than 5 (five) years following the end of provision of services;
  3. messaging data will be retained for no longer than 2 (two) years following the provision of consent or, in case the messaging data is being sent to the present clients for the purpose of maintaining and improving customer relations, for no longer than 2 (two) years following the end of provision of the respective services, unless you respectively withdraw your consent earlier or object to such processing;
  4. correspondence data will be retained for no longer than 6 (six) months following the end of the communication to which the data pertains.
2. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained, e.g. device data will be retained for as much as necessary for the relevant processing purposes.
3. After the end of applicable retention period or upon your request, personal data is destructed using overwriting or physical destruction (when applicable) methods.
4. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Marketing communication
1. Provided you give us your consent, we will contact you via email or phone to inform you about our products, services, and plans. Additionally, if we have already provided services to you and you do not object, we will also inform you via email or phone (when you have provided such) about our Companies or the member Companies that belong to our group, as well as about other products that might interest you.
2. When contacting you by phone as provided in section 4.1. above, SMS/text messages from us will be delivered through your wireless provider to the mobile number you provided. SMS/text messages may be sent using an automatic telephone dialling system or other technology. Message frequency varies. Message and data rates may apply.
3. You may opt out of receiving marketing communications at any time. You may do so by choosing the relevant link in any of our marketing messages or contacting us via means provided on our website. If you are receiving both email and phone marketing communications on the grounds provided in section 4.1. above and you wish to opt out of receiving them, you will need to opt out separately by following the relevant link in any of our marketing messages or contacting us via means provided on our website.
4. Upon you having fulfilled any of the opt-out actions described in the preceding paragraph, we will update your profile to ensure that you don't receive our marketing communication in the future.
5. As our business activities consists of a network of closely related services, please note that it may take a few days until all the systems are updated, thus you may continue to receive marketing communication while we are still processing your opt-out request.
6. Also note that, in any case, the opt-out of the marketing communications will not stop you from receiving communication that is directly related to the provision of the services you're using.
Your rights
1. In this Section, we have summarised the rights that you have under data protection laws. Some of the rights are complex, thus we only provide the main aspects of such rights. Accordingly, you should read the relevant laws (first and foremost the General Data Protection Regulation (EU) 2016/679) and guidance from the regulatory authorities for a full explanation of these rights.
2. Your principal rights under data protection law are the following:
  1. the right to access data;
  2. the right to rectification;
  3. the right to erasure of your personal data;
  4. the right to restrict processing of your personal data;
  5. the right to object to processing of your personal data;
  6. the right to data portability;
  7. the right to complain to a supervisory authority;
  8. the right to withdraw consent; and
  9. the right to request not to be a subject to a decision based solely on automated processing, including profiling.
3. The right to access data. You have the right to confirmation as to whether or not we process your personal data and, where we do, you have the right to access that personal data, together with certain additional information. That additional information includes the details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Provided the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
4. The right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to the erasure of your personal data. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is conducted for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions to the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defence of legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on the aforementioned bases, we may continue to store your personal data; however we will only further process such data: (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but your right to object is limited by the nature of the legal basis for the processing in question. Your right to object will be limited if: the processing is conducted for the performance of a task carried out in the public interest or for the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is needed for the establishment, exercise or defence of legal claims.
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10. The right to data portability. To the extent that the legal basis for our processing of your personal data is:
  1. consent; or
  2. performance of a contract or the steps to be taken at your request prior to entering into a contract, when those steps are necessary to enter into such contract. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11. If you determine that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. Our data processing is supervised by State Data Protection Inspectorate of the Republic of Lithuania, registered office at L. Sapiegos St. 17, LT-10312 Vilnius, www.vdai.lrv.lt
12. When the legal basis for our processing of your personal information is consent, you have the right to withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
13. You have the right to request not to be a subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you significantly. However, there are exclusions to this right. Such exclusions include when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorised by EU or EU member state law to which we are subject to and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; (iii) is based on your explicit consent.
14. In addition to specific measures provided in this Section or on our website, you may also exercise any of the rights indicated herein by contacting us via email at: [email protected]. We undertake to respond to such inquiries within 1 month upon receiving your inquiry. This response time may be extended by 2 months for complex or multiple requests. We will timely inform you of any such extension.
About cookies
1. We will ask you to consent to our use of cookies in accordance with the terms of this notice when you first visit our website.
2. Cookies are small textual files containing identifier that is sent by a web server to your web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
3. Cookies do not typically contain any information that personally identifies a user, but the personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
1. On the website, we use three main types of cookies, for the following purposes:
  1. Required cookies – used to ensure proper performance of the website, security of customers and their data, provision of high-quality services;
  2. Functional cookies – used to enhance the website user experience, analyse the use of the system, and in accordance with such, improve the provision of services;
  3. Advertising cookies – used to observe user online behaviour and optimise marketing campaigns according to such information.
Cookies used by our service providers
1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
2. We may use:
  1. Google Analytics cookies to observe our website traffic. Cookies used for this purpose help us detect website errors as well as measure website bandwidth. You can view the privacy policy of Google Analytics here;
  2. Youtube cookies to display our website content uploaded to Youtube. Cookies used for this purpose help us maintain integrity and create informative and dynamic website. You can view the privacy policy of Youtube here;
  3. Twitter cookies to display our website content posted on Twitter. Cookies used for this purpose help us maintain integrity and create informative and dynamic website. You can view the privacy policy of Twitter here;
  4. Google Maps cookies to, if the user permits, determine user location. Cookies used for this purpose help us adapt website settings in accordance to user’s location and improve user experience on our website. You can view the privacy policy of Google Maps here;
  5. Doubleclick cookies to control the display of ads to our users. Cookies used for this purpose help us to distinguish users that already use our services and to reduce or stop displaying our ads to such users. You can view the privacy policy of Doubleclick here;
  6. Facebook cookies to manage the display of ads to our users. Cookies used for this purpose help us to distinguish users that already use our services and to reduce or stop displaying our ads to such users. You can view the privacy policy of Facebook here;
  7. Google Tag Manager cookies to control advertising cookies. Cookies used for this purpose help us properly distribute ads to users. You can view the privacy policy of Google Tag Manager here;
  8. Hotjar cookies to observe how users use our website. Cookies used for this purpose help us observe the performance of the website and analyse how we can improve our website. You can view the privacy policy of Hotjar here;
  9. Visual Website Optimiser cookies to collect information on how visitors interact with the pages on our website. You can view the privacy policy of Visual Website Optimiser here.
How can you manage cookies?
1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can find up-to-date information about blocking and deleting cookies on the official website of the relevant browser, including Chrome; Firefox; Internet Explorer; Safari.
2. Blocking all cookies will have a negative impact on the usability of our and other websites.
3. If you block cookies, you will not be able to use all the features on our website.
Third-party websites
On our websites, you may find links to and from partner sites, information sources, and related-party websites. Please note that such third-party websites that you visit by clicking on the links on our website have their own privacy policies and we take no responsibility regarding such privacy policies. We recommend familiarising with privacy policies of such websites before providing any personal data to them.
Children personal data
1. Our website and services are targeted at persons over the age of 18.
2. If we have reason to believe that we hold personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.
California Privacy Addendum
If you are a California consumer or resident, in addition to the information provided in this privacy policy, you may have the additional rights and access to information provided to you under the California Consumer Privacy Act:
1. We do not knowingly sell personal information nor share it with third parties for direct marketing purposes. However, if we decide to do so in the future, you will be notified and you will have the right to opt out of the “sale” of personal information;
2. We will retain, use, or disclose personal information that we collect or processes on your behalf only for the purposes described in this privacy policy, and will notify you if this changes.
3. You have the right to not be subject to discrimination if you exercise any of your rights.
We do not currently recognise or respond to browser-initiated Do Not Track signals. The instructions to enable these signals for the following browsers can be found here: Chrome, Firefox, IE, Edge, Safari, Opera.
Updating your data
Please let us know if the personal information that we hold about you needs to be corrected or updated.
Changes to the notice
Any changes to this notice will be published on our website and, in case of material changes, we may inform you about such via email or by other means that we deem the most fitting in a particular case.

Last modified 30/08/2022.