Privacy Policy
Last Updated: August 4, 2025
Our Commitment to You
Lean Labs Ltd. trading as SlimminGood, together with its
subsidiaries and affiliated companies (collectively,
“SlimminGood”, "Company", "we" or "us"),
is devoted to making sure that your privacy rights are respected, and
personal data is collected and used in accordance with the current and
applicable privacy and data protection law.
SlimminGood develops and markets health and wellness products designed
to assist in weight management and overall health improvement. Our
offerings include dietary supplements, meal plans, fitness programs,
and related services (the “Product/s”).
As part of that, we operate promotional websites and landing pages,
including
https://slimmingood.com/,
allowing prospective customers and other site visitors to receive
information about the Product and our proposal, contact us, subscribe
to our marketing materials lists, etc. (“Site”). The Product
and Site shall be referred to, collectively, as the “Services”.
This privacy policy (“Privacy Policy”) explains what data we
collect when using our Services, how such data may be used or shared
with others, how we safeguard it, and how you may exercise your rights
related to your Personal Data (as defined below), as required under
applicable data protection laws. The Privacy Policy provides details
regarding the processing of Personal Data in connection with:
-
“Visitors”: Individuals who visit or otherwise interact with the Site,
including with our proposed quizzes and other marketing materials.
-
“Customers”: Individuals who purchase the Product and Services through the
Site.
Visitors and Customers shall be further, separately and collectively,
referred herein as “you”.
This Privacy Policy is an integral part of any other agreement between
you and us, including the Terms and Conditions available at
https://lp.slimmingood.com/ndr/terms-and-conditions, incorporated here by reference (“Terms”). Any term not defined
herein shall have the meaning ascribed to such term under the Terms or
where applicable under the relevant privacy regulation, especially the
EU General Data Protection Regulation known as the “GDPR”.
US States Residents Notice: If you are a U.S.
resident, please review our U.S. Privacy Notice to
learn more about our privacy practices in accordance with applicable
U.S. state privacy laws, including the specific disclosures required
under the California Consumer Privacy Act of 2018 ("CCPA"), which may
apply to you based on your state of residency.
1. CHANGES TO THE PRIVACY POLICY
We reserve the right to change this Privacy Policy occasionally, at
our sole discretion. The most recent version of the Privacy Policy
will always be posted on the website, and the update date will be
reflected in the “Last Modified” heading. We will notify you if these
changes are material, and, where applicable law requires, we will
obtain your consent. Any material amendments to the Privacy Policy
will become effective within 30 days upon the display of the modified
Privacy Policy.
We recommend you review this Privacy Policy periodically to ensure
that you understand our most updated privacy practices.
2. CONTACT INFORMATION AND DATA CONTROLLER INFORMATION FOR UK GDPR
PURPOSES
SlimminGood is the “Data Controller” or “Business” (as such term is
defined under applicable privacy legislation) of Personal Data
pertaining to you.
If you have any questions, inquiries, requests, or concerns related to
this Privacy Policy and our privacy practices or the processing of
your Personal Data by us, you may contact our privacy team as follows:
Representative for Data Subjects in the UK Contact Information:
Per UK GDPR, we have appointed Prighter as our UK Data Protection
Representative. The DPR contact details are: Prighter Maetzler
Rechtsanwalts GmbH & Co KG, a company registered under FN 502860a with
the companies register of the Vienna commercial court, 1010 Vienna,
Austria. To verify, please see:
https://prighter.com/q/14155658620.
3. DATA SETS WE COLLECT AND FOR WHAT PURPOSE
You will find below information regarding the types of data we
collect, the purposes for which we process your data as well as our
lawful basis for processing (where the GDPR applies to your data).
We collect two types of data, depending on your interaction with us:
“Non-Personal Data” meaning aggregated,
non-identifiable information, which may be made available or
gathered via your access to and interactions with the Services. We
are not aware of the identity or other identifiers of the individual
from which the Non-Personal Data is collected. The Non-Personal Data
being collected may include aggregated usage information, such as
views of certain Site pages and actions on the Site, or statistical
analysis regarding the use of the Product or the App), as well as
technical information transmitted by your device, such as the type
of browser or device, type of operation system, device settings and
technical software data, etc.
“Personal Data” or “Personal Information” meaning,
individually identifiable information, namely information that
identifies an individual or may, with reasonable effort, be used to
identify an individual. For avoidance of doubt, any Non-Personal
Data connected or linked to any Personal Data shall be deemed as
Personal Data as long as such connection or linkage exists.
Applicable privacy legislation defines a sub-category of Personal
Data, pertaining to "Special Categories of Data" or "Sensitive Data,"
which includes inter alia health-related data ("Sensitive Data"). Such
data may be collected, processed, and used through our Site and
Product, for providing you with our Services as detailed below.
The tables below detail the processing of Personal Data we collect,
the purpose, lawful basis, and processing operations:
Data Sets |
Purpose and Operations |
Lawful Basis (Where the UK GDPR applies) |
Contact Communications: In the event you
contact us for learning more about our product or with any
other inquiry, either through the online forms available on
the Site, by sending us an email, or by other means of
communication we make available, you will be requested to
provide us with your name, email address, phone number, and
any other information you choose to share with us.
|
We process such data solely for the purpose of contacting you,
responding to your inquiries, and providing you with the
support or information you have requested. The correspondence
with you may be processed and stored by us to improve our
customer service, and in the event, we reasonably determine it
is needed for future assistance or to handle any dispute you
might have with us.
|
We process such Contact Communications data subject to our
legitimate interest in order to respond to your inquiry and as
part of our internal record-keeping.
|
Quiz Data: We collect data during the quiz
phase including gender, age, weight, height, target weight,
challenges in life (e.g., headaches, insomnia, fatigue, back
pain, low energy, sleep issues, night cravings, brain fog,
fungus), and digestive conditions (e.g., bloating, nausea,
diarrhea). This may include Sensitive Data, subject to
applicable law and provided voluntarily.
|
We use Quiz Data to fit you with our optimal Product in light
of your characteristics and needs.
We may retain and use
Quiz Data in a de-identified form that does not allow your
identification, for further internal research and development
purposes.
|
Initially, we process such data subject to our legitimate
interest in order to provide you with customized Product and
business proposals. Unless you make a purchase and become a
Customer, such data will be deleted shortly. If you
become a Customer, such data will be retained by us as part of
the Contract between us to provide you with our Services.
|
Video Interaction Data: We collect data on
your interaction with videos, including cookies and other
interaction data.
|
We collect such data through the use of cookies and similar
technologies (see below regarding “Online Identifiers”), for
the purpose of monitoring your usage of the Services and your
interaction with the Site while you watch our movies.
|
We process this data based on your consent obtained through
our cookie notice and consent management toolbar.
|
Payment Data: When you make a purchase, we
may keep transactional data, such as Invoice Data (full name,
address, zip code), purchased Products, transaction date and
time, information related to fraud prevention, means of
payment data, etc.
|
Through Digistore24 and Shopify, we collect payment data to
complete your purchase, collect payment and provide you with
the Products you have purchased.
|
We process this data to fulfill our contract with you. |
Product Interaction Data: After purchasing,
we collect data on your interaction with the product,
interfaces, emails, and other related communications. This
includes data on how you use our products and services,
feedback, and any issues encountered.
|
We collect such data to manage your purchases, deliver our
Services to you, measure and improve our services, and propose
new services and offerings.
|
We process such data based on our legitimate interest in
improving our services and customer experience, and to fulfill
our contract with you, where such data is processed as part of
a purchased Product.
|
Online Identifiers and Usage Data: When you
access our Site, we may collect certain online identifiers
such as IP address, Device ID, cookie ID and other similar
identifiers (“Online Identifiers”). We may further collect
information related to your use and interaction with our Site
such as directing campaign and URLs, pages viewed, access time
and date, duration, clickstream, WiFi network, DNS name,
screen resolution, device type and model, etc. (
“Site Usage
Data”
).
|
We process Online Identifiers and Site Usage Data through our
or third-party services and tracking technologies for
analytic, marketing and advertising purposes.
For
example, we process this data to understand how Visitors use
our Site, personalize the Services for you and your
preferences as well as to measure effectiveness of our
features and content.
In addition, Site Usage Data
helps us to better understand our business, analyze our
operations, maintain, improve, design, and develop the
Service, conduct statistical analysis, etc.
Further,
Site Usage Data is used sometimes for operation, Site
functionality, security and fraud prevention and debugging
purposes, and to resolve technical problems.
|
Where we collect Online Identifies or Site Usage Data for
analytic and advertising purposes, we process such data based
on your consent obtained through our cookie notice and consent
management toolbar. You may withdraw consent or change your
preferences at any time by using the cookie settings tool
available on our Site.
Where we collect Online
Identifiers or Site Usage Data for operation and security
purposes, we process your data based on our legitimate
interest.
|
Newsletter Registration: In the event you
register for our newsletter or direct marketing
communications, you will be requested to provide us with your
email address, phone number, and any other information you
choose to share with us.
|
We process such data to register you as a recipient of our
newsletter, updates, and news about SlimminGood and the
Services. We may further process your data to send you needed
information related to our webinars, additional occasional
communications, and updates related to our Services,
promotional and marketing emails (i.e., Direct Marketing).
|
We process such information subject to our legitimate
interest. Direct Marketing is further based on our legitimate
interest, and you may opt-out at any time through the
“unsubscribe” link within the email or by contacting us
directly. For SMS marketing, we obtain your consent where
required by law.
|
Please note that the actual processing operation per
each purpose of use and lawful basis detailed in the table above may
differ, and we are only responsible for the Personal Data we collect
and process as the controller of the Personal Data. Such processing
operation usually includes a set of operations made by automated
means, such as collection, storage, use, disclosure by transmission,
erasure, or destruction.
The transfer of Personal Data to third-party countries, as further
detailed in the “Data Transfer” Section below, is based on the same
lawful basis as stipulated in the table above.
4. HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Site and
Services, we may collect information as follows:
-
Automatically - we may use cookies (as elaborated
in the section below) or similar tracking technologies (such as
pixels, tags, agent, etc.) to gather some information automatically.
-
Provided by you or about you voluntarily - we will
collect information if and when you choose to provide us with the
information, such as through the Quiz Data, contact us
communications, etc.
-
Information we receive from third parties - for
example, through data enrichment partners or if you access the
Services through a third-party connection or log-in, such as your
social media accounts, etc.
5. SHARING INFORMATION WITH THIRD PARTIES
We share your Personal Data with third parties, including our
affiliated companies and subsidiaries, as well as service providers
that help us provide our Services. You can find in the table below
information about the categories of such third-party recipients.
Category of Recipient |
Data That Will Be Shared |
Purpose of Sharing |
Service Providers |
All types of Personal Data |
We share Personal Data with our trusted agents (such as legal
counsel) and service providers (including, but not limited to,
our Cloud Service Provider, Analytics Service Provider, CRM
provider, etc.) so that they can perform the requested
services on our behalf. Thus, we share your data with third
party entities, for the purpose of storing such information on
our behalf, or for other processing needs. These entities are
prohibited from using your Personal Data for any purposes
other than providing us with requested services
|
Digistore24 |
Payment and Purchase data |
When you make a purchase or provide financial information on
our Site, your data may be collected and processed directly by
Digistore24, and their data processing practices will be
governed by their own privacy policy.
|
Any acquirer of our business |
All types of Personal Data |
We may share Personal Data, in the event of a corporate
transaction (e.g., sale of a substantial part of our business,
merger, consolidation or asset sale). In the event of the
above, our affiliated companies or acquiring company will
assume the rights and obligations as described in this Policy.
|
Affiliated companies |
All types of Personal Data |
We may share Personal Data with our affiliated companies in
accordance with the terms of this Policy and for the purpose
of providing the Services.
|
Legal and law enforcement |
Subject to law enforcement authority request |
We may disclose certain data to law enforcement, governmental
agencies, or authorized third parties, in response to a
verified request relating to terror acts, criminal
investigations or alleged illegal activity or any other
activity that may expose us, you, or any other user to legal
liability, and solely to the extent necessary to comply with
such purpose.
|
For avoidance of doubt, we may transfer and disclose or otherwise use
Non-Personal Information or information which is linked to anonymous
random identifiers or information that is aggregated in a
non-identifiable way, at our own discretion.
6. COOKIES POLICY
When you access or use the Site or the Dashboard, we use “cookies” or
similar tracking technologies, which store certain information on your
device (i.e., locally stored). The use of cookies is a standard
industry-wide practice. A “cookie” is a small piece of information
that a website assigns and stores on your computer while you are
viewing a website. Cookies are used by us for various purposes,
including allowing you to navigate between pages efficiently, as well
as for statistical purposes, analytic purposes and advertising. You
can find more information about our use of cookies here:
www.allaboutcookies.org.
You can always review the list of Cookies on our Site and control your
cookie preferences by the designated cookies tool available on our
Site.
Also note that, most browsers will allow you to erase cookies from
your computer's hard drive, block acceptance of cookies, or receive a
warning before a cookie is stored. You may set your browser to block
all cookies, including cookies associated with our Site and Services,
or to indicate when a cookie is being used by us, by adjusting the
privacy and security settings of your web browser. Please refer to the
support page of your browser to learn more about how you can adjust
your privacy and security settings. Please note that once you choose
to opt-out or disable cookies, some features of the Services may not
operate properly and your online experience may be limited. In
addition, even if you opt-out, you may still receive some content and
advertising, however, it will not be targeted content or advertising.
Where we use third-party advertising cookies, such third-party may
independently collect, through the use of such tracking technologies,
some or all types of Personal Data detailed above, as well as
additional data sets, including to combine such information with other
information they have independently collected relating to your online
activities across their network of websites, for the purpose of
enhanced targeting functionality and delivering personalized ads, as
well as providing aggregated analytics related to the performance of
our advertising campaign you interacted with. These third parties
collect and use this information under their own privacy policies, and
are responsible for their practices.
7. DATA RETENTION
We retain the Personal Data we collect as long as it remains necessary
for the purposes set forth above, all in accordance with applicable
regulation, or until an individual expresses a preference to opt-out.
Please note that certain Customer data may be retained without
limitation as such data is also part of our internal record keeping as
a business.
Other circumstances in which we will retain your Personal Data for
longer periods of time include: (i) where we are required to do so in
accordance with legal, regulatory, tax, or accounting requirements;
(ii) for us to have an accurate record of your dealings with us in the
event of any complaints or challenges; or (iii) if we reasonably
believe there is a prospect of litigation relating to your Personal
Data. Please note that except as required by applicable law, we may at
our sole discretion, delete or amend information from our systems,
without notice to you, once we deem it is no longer necessary for such
purposes.
8. DATA SECURITY
We work hard to protect the Personal Data we process as part of our
Services from unauthorized access, alteration, disclosure, or
destruction. We have implemented physical, technical, and
administrative security measures that comply with applicable laws and
industry standards, such as encryption, access restrictions and
permissions, etc.
Note that we cannot be held responsible for unauthorized or unintended
access beyond our control, and we make no warranty, express, implied,
or otherwise, that we will always be able to prevent such access.
Therefore, without derogating from our obligations under applicable
law, you, including any Customer, remain fully responsible for the
security of the data processed through the Services.
9. CROSS BORDER DATA TRANSFER
Due to our global business operation, we may store or process your
Personal Data in the United States or in other countries. Thus, any
information you provide to us may be transferred to and processed in
countries other than the country from which you accessed our Service.
In the event that we need to transfer your Personal Data out of your
jurisdiction, we will take appropriate measures to ensure that your
Personal Data receives an adequate level of protection as required
under applicable law.
When Personal Data that is collected within the European Economic Area
(“EEA“) is transferred outside of the EEA to a country that has not
received an adequacy decision from the European Commission or relevant
applicable law (e.g., UK's), we will take necessary steps in order to
ensure that sufficient safeguards are provided during the transferring
of such Personal Data, in accordance with the provision of the
standard contractual clauses approved by the European Union. Thus, we
will obtain contractual commitments or assurances from the data
importer to protect your Personal Information, using contractual
protections that EEA and UK regulators have pre-approved to ensure
your data is protected (known as standard contract clauses), or rely
on adequacy decisions issued by the European Commission. Some of these
assurances are well-recognized certification schemes.
10. YOUR RIGHTS
We acknowledge that different people have different privacy concerns
and preferences. Our goal is to be clear about what information we
collect, so that you can make meaningful choices about how it is used.
We provide you with the ability to exercise certain choices, rights,
and controls in connection with your Personal Data. Depending on your
relationship with us (e.g., if you are a visitor of the Site or a
Customer), your jurisdiction, and the applicable data protection laws
that apply to you, you have the right to control and request certain
limitations or rights to be executed. Under the UK-GDPR, these rights
include the right to access your Personal Data, the right to rectify
inaccurate or incomplete data, the right to erasure (also known as the
"right to be forgotten"), the right to restrict processing, the right
to data portability, the right to object to processing, and the right
not to be subject to a decision based solely on automated processing,
including profiling. We are committed to facilitating the exercise of
these rights and ensuring that your privacy preferences are respected.
For detailed information on your rights and how to exercise your
rights, please see the Data Subject Request (“DSR”) form available
here and send it to our privacy team at:
support@slimmingood.com.
Certain rights can be easily executed independently by you without the
need to fill out the DSR form, for example:
-
You can opt-out from receiving our marketing emails by clicking
“unsubscribe” link;
-
You can use the cookie settings tool on our website to change your
preferences.
If you are an EU or UK resident, you may also submit the request to
exercise your right to our Data Protection Representative as explained
above.
Where we are not able to provide you with the information for which
you have asked, we will endeavor to explain the reasoning for this and
inform you of your rights, including the right to complain to the
supervisor authority (in the event you are an EEA resident). We
reserve the right to ask for reasonable evidence to verify your
identity before we provide you with any such information in accordance
with applicable law.
In the event you are a Customer - note that termination of the
engagement or stopping use of the Product does not automatically
resolve in deletion of data. If you wish to delete the data, please be
sure to contact us with such a request.
For more US-related privacy rights, please review our
U.S. Privacy Notice.
11. PROTECTING CHILDREN
Our Site as well as the Services are not intended for users under the
age of eighteen (18). Therefore, we do not intend and do not knowingly
collect Personal Data from children. We will discard any information
we receive from a user that is considered a "child" immediately upon
discovering that such a user shared information with us. Please
contact us at:
support@slimmingood.com
if you have reason to believe that a child has shared any information
with us.
12. LINKS TO OTHER WEBSITES AND THIRD-PARTY PRACTICES
The Site may contain links to third-party websites. It is our intent
to provide links only to other quality websites. However, we have no
control over these linked websites or, for that matter, any third
parties. Any information collected by websites, other than the Site,
is not covered by this Privacy Policy. We are not responsible for the
content or privacy and security practices and policies of any third
parties, including other websites that may be linked to or from the
Site. We encourage you to read the provisions of privacy policies on
other websites before providing them with your personal information.