Privacy Policy

1. Who we are and what this policy covers

This Privacy Policy explains how we handle your personal data on nutrivial.com and in our services. The general part applies to everyone. The service parts apply depending on what you use:

• Part A applies if you book coaching. Premium, Classic and Lite Coaching include access to the Nutrivial tool, so Part B then applies as well. One-Time Coaching does not include tool access.
• Part B applies if you use the Nutrivial nutrition analysis tool.

We comply with the Swiss Federal Act on Data Protection (FADP) and, where it applies, the EU General Data Protection Regulation (GDPR).

Controller: Olivier Schalbetter, trading as Nutrivial, 8280 Kreuzlingen, Switzerland
Email: health@nutrivial.com
Phone: +41 77 291 87 67

Only adults aged 18 and over can hold an account. Parents or legal guardians can add profiles for their children to their own tool account (see Section 11).

2. Data we collect from everyone

• Account and contact data: name, email address, phone number, billing address.
• Payment data: processed by Stripe. We receive payment status and the last four digits of your card, never your full card details.
• Technical data: IP address, browser and device type, and server logs needed to run the website and the tool securely (see Section 7).

The data we collect for coaching and for the Nutrivial tool is described in Parts A and B.

3. Legal basis

Under the FADP, we process your data in line with its principles and, for health data, on the basis of your explicit consent.

4. Health data and your consent

We process health data only with your explicit consent, which you give through a separate checkbox when you book coaching or sign up for the Nutrivial tool. Your consent covers only the services you use. We use health data only to deliver those services. We never use it for advertising and never sell it.

You can withdraw your consent at any time by email to health@nutrivial.com. Processing before the withdrawal remains lawful. As our services cannot be provided without health data, withdrawal ends the affected service at the end of the current billing period.

Our coaching and the Nutrivial tool do not replace medical advice, diagnosis or treatment.

5. Who receives your data

We do not sell your data. We share it only with service providers who help us run our services and who are bound by data processing agreements and confidentiality. These providers are used for all our services; providers used only for coaching or only for the tool are listed in Parts A and B.

Stripe also acts as an independent controller for some payment data, such as fraud prevention; its own privacy policy applies to that processing. We may also disclose data where the law requires it, for example to tax authorities.

6. Transfers abroad

Some providers process data outside Switzerland and the EU, mainly in the USA. We transfer data only where the recipient country has adequate data protection as recognised by the Swiss Federal Council or the European Commission, or where suitable safeguards are in place. For the USA, these are the Swiss–US and EU–US Data Privacy Frameworks for certified providers, otherwise Standard Contractual Clauses. You can request a copy of the safeguards from us.

7. Cookies

We use only technically necessary cookies, for example to keep you logged in and to remember your cookie choices. We do not use analytics, advertising or tracking cookies. If we introduce them in future, we will ask for your consent through our cookie banner first and update this policy.

8. Data we collect for coaching

• Health data: information you give us in the intake questionnaire, during sessions and in messages, such as goals, eating habits, sleep, stress, activity, health conditions and medication you choose to tell us about.
• Coaching records: session notes, written summaries, check-in messages and booking details. Questionnaires are stored on a server in Frankfurt, Germany; session notes are kept on our coaches’ encrypted computers.

You are not required to provide health data. Without it, however, we cannot provide coaching.

9. Video sessions and messaging

Appointments are booked through Google Calendar, which sends your confirmation and the call link. Video sessions take place via Google Meet. For check-ins between sessions you can choose WhatsApp or Signal. Both encrypt message content end to end, so the providers cannot read it. They do, however, process metadata such as phone numbers and when messages are sent, and WhatsApp shares some of this with other Meta companies. If you prefer to keep this to a minimum, we recommend Signal. Please do not send information through these apps that you would not want stored on your phone.

10. How long we keep coaching data

11. Data we collect in the tool

• Profile data: age, sex, height, weight, activity level, sleep hours, diet type, smoking and pregnancy status.
• Nutrition data: food logs, recipes and the analyses and reports produced from them.

We treat pregnancy status and details such as weight, activity and sleep as health data. You are not required to provide them. Without them, however, the tool cannot produce personalised analyses.

Children’s profiles. Parents or legal guardians can add profiles for their children aged 4 to 17 to their own account. Children cannot hold an account themselves. By adding a child’s profile, the parent or guardian confirms that they are entitled to act for the child, provides the child’s data and consents to its processing on the child’s behalf, and is responsible for that data. Children’s data is processed and kept in the same way as adult profile data, except that weight-loss goals, calorie targets and pregnancy status are not available in children’s profiles.

12. Automated reports

Nutrivial reports are generated automatically from your profile and nutrition data. They are recommendations only and do not lead to decisions with legal or similarly significant effects on you. Parts of the report text are written with the help of OpenAI. For this, we send OpenAI only the report content it needs to write or summarise the relevant sections. This never includes your contact details or profile data, and OpenAI does not use it to train its models.

13. Providers used for the tool

14. How long we keep tool data

15. Other retention periods

16. Security

We protect your data with technical and organisational measures appropriate to its sensitivity, including encrypted transmission (TLS), encrypted storage of health data on our servers and on our devices, access restricted to the coach working with you, strong passwords with two-factor authentication on all systems, and regular backups.

17. Your rights

You have the right to:

• know whether we process your data and receive a copy of it
• have inaccurate data corrected
• have your data deleted
• restrict or object to processing
• receive your data in a common, machine-readable format (data portability)
• withdraw your consent at any time, with effect for the future

To exercise your rights, email health@nutrivial.com. We reply within 30 days and may ask you to confirm your identity.

18. Complaints

If you believe we are handling your data unlawfully, please contact us first. You can also complain to a supervisory authority: in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch); in the EU, the data protection authority in your country of residence, for example the data protection authority of your German federal state or the Austrian Data Protection Authority (dsb.gv.at).

19. Changes to this policy

We may update this policy when our services or the law change. We will inform active clients and tool users of material changes by email. The current version is always available on our website.