Privacy policy


Last Updated: 09-04-2023


Our Commitment to You


Livingood Daily Inc. trading as SlimminGood, together with its subsidiaries and affiliated companies including SlimminGood, LLC. (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 to 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/site/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@drlivingood.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@drlivingood.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.