Last modified: March 13, 2025

Introduction

NUTSON INC with its registration number 3140473 and registered address at 251 Little Falls

Drive, Wilmington, DE 19808, USA ("Company" or "We") respect your privacy and are

committed to protecting it through our compliance with this policy.

This privacy policy aims to give you information on how collects and process your personal data

through your use of our websites www.nutson.us and the apps, including any data you may provide

through this website when you sign up to our newsletter, purchase a product or service or take part

in a competition.

This policy also describes:

● The types of information we may collect or that you may provide when you purchase,

download, install, register with, access, or use the apps (the "Apps").

● Our practices for collecting, using, maintaining, protecting, and disclosing that

information.

Please read this policy carefully to understand our policies and practices regarding your

information and how we will treat it. If you do not agree with our policies and practices, do not

download, register with, or use this App or website. By downloading, registering with, or using

this App, you agree to this privacy policy. This policy may change from time to time (see Changes

to Our Privacy Policy). Your continued use of this App after we revise this policy means you

accept those changes, so please check the policy periodically for updates.

Controller

In terms of the GDPR and UK GDPR NUTSON EU LIMITED and its affiliates is the data

controller and responsible for your personal data (also referred as "Company", "we", "us" or "our"

in this privacy policy).

Our authorised representative under article 27 GDPR in the EU is Elena Riazanova with her postal

address Cullera 11, 3C, Madrid, Spain.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us at

[email protected]

Children Under the Age of 13

The Apps and websites are not intended for children under 13 years of age, and we do not

knowingly collect personal information from children under 13. If we learn we have collected or

received personal information from a child under 13 without verification of parental consent, we

will delete that information. If you believe we might have any information from or about a child

under 13, please contact us at [email protected].

California residents under 16 years of age may have additional rights regarding the collection and

sale of their personal information. Please see Your California Privacy Rights section for more

information.

Information We Collect and How We Collect It

We collect information from and about users of ours Apps and websites:

● Directly from you when you provide it to us.

● Automatically when you use the Apps and websites.

Information You Provide to Us

When you download, register with, or use our Apps or upload your content we may ask you

provide some information:

● By which you may be personally identified, such as name, email address, telephone number

any other identifiers by which you may be contacted online or offline or ANY OTHER

INFORMATION THE APP COLLECTS THAT IS DEFINED AS PERSONAL OR

PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW

("personal information").

● That is about you but individually does not identify you.

This information includes:

● Information that you provide by filling in forms in the Apps. This includes information

provided at the time of registering to use the Apps, subscribing to our services, posting

material or requesting further services. We may also ask you for information when you

enter a contest or promotion sponsored by us, or when you report a problem with the Apps.

● Records and copies of your correspondence (including email addresses and phone

numbers), if you contact us.

● Your responses to surveys that we might ask you to complete for research purposes.

● Details of transactions you carry out through the Apps and of the fulfillment of your orders.

You may be required to provide financial information before placing an order through the

Apps.

● Your search queries on the Apps.

You may also provide information for publication or display ("Posted") on public areas of the app

or websites you access through the Apps/Websites (collectively, "User Content"). Your User

Content is Posted and transmitted to others at your own risk. Additionally, we cannot control the

actions of third parties with whom you may choose to share your User Content. Therefore, we

cannot and do not guarantee that your User Contributions will not be viewed by unauthorized

persons.

Automatic Information Collection and Tracking

When you download, access, and use the Apps, they may use technology to automatically collect:

● Usage Details. When you access and use the Apps, we may automatically collect certain

details of your access to and use of the App, including traffic data, logs, and other

communication data and the resources that you access and use on or through the Apps.

● Device Information. We may collect information about your mobile device and internet

connection, including the device's operating system, browser type, mobile network

information..

● Stored Information and Files. The App also may access metadata and other information

associated with other files stored on your device. This may include, for example,

photographs, audio and video clips, personal contacts, and address book information if you

allow the app to access this data in order to operate correctly.

If you do not want us to collect this information do not download the App or delete it from your

device.

We also may use these technologies to collect information about your activities over time and

across third-party websites, apps, or other online services (behavioral tracking). Click here

www.aboutads.info for information on how you can opt out of behavioral tracking on or through

this app and how we respond to browser signals and other mechanisms that enable consumers to

exercise choice about behavioral tracking.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

● Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or laptop.

It may be possible to refuse to accept mobile cookies by activating the appropriate setting

on your smartphone. However, if you select this setting you may be unable to access certain

parts of our App.

● Web Beacons. Pages of the App and our emails may contain small electronic files known

as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit

the Company, for example, to count users who have visited those pages [or opened an

email] and for other related app statistics (for example, recording the popularity of certain

app content and verifying system and server integrity).

Third-Party Information Collection

When you use the Apps or its content, certain third parties may use automatic information

collection technologies to collect information about you or your device. These third parties may

include:

● Analytics companies.

● Advertisers, ad networks, and ad servers.

● Your mobile device manufacturer.

● Your mobile service provider.

Third party vendors, including Google, use cookies and similar technologies to serve ads based on

a user's prior visits to your website or other websites.

Google's use of advertising cookies enables it and its partners to serve ads to your users based on

their visit to your sites and/or other sites on the Internet.

You may opt out of personalized advertising by visiting Google Ads Settings or opt out of a third-

party vendor's use of cookies for personalized advertising by visiting www.aboutads.info.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal

information, to:

● Allow users to create accounts and to use our Services.

● Provide you with the Apps and their contents, and any other information, products or

services that you request from us.

● Fulfill any other purpose for which you provide it.

● Give you notices about your account/subscription, including expiration and renewal

notices.

● Carry out our obligations and enforce our rights arising from any contracts entered into

between you and us, including for billing and collection.

● Notify you when Apps updates are available, and of changes to any products or services

we offer or provide though it.

The usage information we collect helps us to improve our Apps and to deliver a better and more

personalized experience by enabling us to:

● Estimate our audience size and usage patterns.

● Store information about your preferences, allowing us to customize our Apps according to

your individual interests.

● Speed up your searches.

● Recognize you when you use the Apps.

We may also use your information to contact you about our goods and services that may be of

interest to you and subject to your consent.

We have set out below, in a table format, a description of all the ways we plan to use your personal

data, and which of the legal bases we rely on to do so for EU based users.

Purpose/Activity

Type of data

Lawful basis for processing

including basis of legitimate

interest

To register you as a new user

(a) Identity

(b) Contact

Performance of a contract (user

agreement) with you

To process and deliver your

order including:

(a) Manage payments, fees

and charges

(a) Identity

(b) Contact

Performance of a contract (user

agreement) with you

To manage our relationship

with you which will include:

(a) Notifying you about

changes to our terms or

(b) Asking you to leave a

review or take a survey

(a) Identity

(b) Contact

(d) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal

obligation

interests (to keep our records updated

and to study how customers use our

products/services)

To enable you to partake in a

prize draw, competition or

complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate

interests (to study how customers use

our products/services, to develop

them and grow our business)

To administer and protect our

business, websites and Apps

(including troubleshooting,

data analysis, testing, system

maintenance, support,

reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate

interests (for running our business,

provision of administration and IT

services, network security, to prevent

fraud and in the context of a business

reorganisation or group restructuring

exercise)

(b) Necessary to comply with a legal

obligation

To deliver relevant websites

and Apps content and

advertisements to you and

measure or understand the

effectiveness of the

advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and

Communications

(f) Technical

Necessary for our legitimate interests

(to study how customers use our

products/services, to develop them, to

grow our business and to inform our

marketing strategy)

To use data analytics to

improve our websites and

Apps, products/services,

marketing, customer

relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests

(to define types of customers for our

products and services, to keep our

website updated and relevant, to

develop our business and to inform

our marketing strategy)

To make suggestions and

recommendations to you

about goods or services that

may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and

Communications

Necessary for our legitimate interests

(to develop our products/services and

grow our business)

For marketing purposes in

order to compile User ratings,

and to provide rating

information to the general

public on the Website and App

(a) Profile

(b) Transactions

It is necessary for making ratings of

Users, increasing the interest of Users

to the App, as well as increasing the

popularity of individual Users who

occupy leading positions in the

ratings, according to the use of the

functionality of the App

Disclosure of Your Information

We may disclose personal information that we collect or you provide:

● To our subsidiaries and affiliates.

● To service providers, and other third parties we use to support our business and who are

bound by contractual obligations to keep personal information confidential and use it only

for the purposes for which we disclose it to them, for example our hosting provider Amazon

Web Services.

● To a buyer or other successor in the event of a merger, divestiture, restructuring,

reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as

a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which

personal information held by us about our Apps users is among the assets transferred.

● To fulfill the purpose for which you provide it. For example, if you give us an email address

to use the "email a friend" feature of our Websites or Apps, we will transmit the contents

of that email and your email address to the recipients.

● For any other purpose disclosed by us when you provide the information.

● To comply with any court order, law, or legal process, including to respond to any

government or regulatory request.

● To enforce our rights arising from any contracts entered into between you and us, including

the Terms of use

● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety

of the Companies, our customers or others. This includes exchanging information with

other companies and organizations for the purposes of fraud protection and credit risk

reduction.

● For marketing purposes and dissemination of a limited amount of personal data to which

the User has provided his/her consent in accordance with the Privacy Policy in order to

familiarize other users with the results of using the App.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This

section describes mechanisms we provide for you to control certain uses and disclosures of over

your information.

● Tracking Technologies. You can set your browser to refuse all or some browser cookies,

or to alert you when cookies are being sent. If you disable or refuse cookies or block the

use of other tracking technologies, some parts of the App may then be inaccessible or not

function properly.

● Targeted Advertising by the Company. If you do not want us to use information that we

collect or that you provide to us to deliver advertisements according to our advertisers'

target-audience preferences, you can opt-out by opt out by visiting www.aboutads.info. Also

you can opt out of receiving targeted ads from members of the Network Advertising

Initiative ("NAI") on the NAI's website.

California residents may have additional personal information rights and choices. Please see Your

California Privacy Rights section for more information.

Your Legal Rights

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Apps and visiting your

account profile page.

You may also send us an email at [email protected] to request access to, correct, or delete any

personal information that you have provided to us. We cannot delete your personal information

except by also deleting your user account. We may not accommodate a request to change

information if we believe the change would violate any law or legal requirement or cause the

information to be incorrect.

You may also request the deletion and correction of parts of your personal data and restrict their

dissemination on the website. If you delete part of your personal data, We will continue to process

the remaining personal data provided by you.

If you delete your User Content from the Apps, copies of your User Content may remain viewable

in cached and archived pages, or might have been copied or stored by other Apps users. Proper

access and use of information provided on the Apps, including User Content, is governed by our

In some of the jurisdictions including EEA area and United Kingdom You may have

additional rights to:

Request access to your personal data (commonly known as a "data subject access request"). This

enables you to receive a copy of the personal data we hold about you and to check that we are

lawfully processing it.

Object to processing of your personal data where we are relying on a legitimate interest (or those

of a third party) and there is something about your particular situation which makes you want to

object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing

purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to

process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend

the processing of your personal data in the following scenarios:

● If you want us to establish the data's accuracy.

● Where our use of the data is unlawful but you do not want us to erase it.

● Where you need us to hold the data even if we no longer require it as you need it to

establish, exercise or defend legal claims.

● You have objected to our use of your data but we need to verify whether we have

overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or

a third party you have chosen, your personal data in a structured, commonly used, machine-

readable format. Note that this right only applies to automated information which you initially

provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw

your consent. If you withdraw your consent, we may not be able to provide certain products or

services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to make a complaint at any time to your local supervisory authority. We would, however,

appreciate the chance to deal with your concerns before you approach the supervisory authority so

please contact us in the first instance.

Data Security

We have implemented measures designed to secure your personal information from accidental loss

and from unauthorized access, use, alteration, and disclosure. All information you provide to us is

stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or

where you have chosen) a password for access to certain parts of our Apps, you are responsible

for keeping this password confidential. We ask you not to share your password with anyone. We

urge you to be careful about giving out information in public areas of the Apps like message

boards. The information you share in public areas may be viewed by any users of the Apps.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat

our users' personal information, we will post the new privacy policy on this page with a notice that

the privacy policy has been updated or notify you with an in-App alert the first time you use the

App after we make the change.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

[email protected].

1. CCPA/CPRA NOTICE AT COLLECTION

- ANNEX 1 -

This California Notice at Collection is provided to California residents pursuant to the California

Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100 et seq.), as amended by the California

Privacy Rights Act of 2020 (Proposition 24). This notice describes the categories of personal

information we collect, the purposes for which we collect it, and whether we sell or share such

information.

1. GENERAL PROVISIONS AND CATEGORIES OF PERSONAL DATA COLLECTED

1.1. Scope. This California Notice at Collection is an integral part of our Privacy Notice and

applies exclusively to residents of California. It does not extend to individuals residing in

other states or countries.

1.2. Precedence. If any provisions of this notice conflict with our general Privacy Notice, the

terms of this California Notice at Collection shall prevail for California residents.

1.3. Data Categories and Classification. Pursuant to Section 1798.130 of the CCPA, we classify

the personal information we collect using specific category names as mandated by law. The

table below outlines these categories along with the corresponding data types as described in

our Privacy Notice.

CPA-Defined

related technical problems.

new features and technologies to improve user experience.

(d) Marketing and Advertising – Delivering personalized promotional content, targeted

advertisements, and marketing campaigns.

(e) Legal and Regulatory Compliance – Meeting statutory obligations, responding to law

enforcement requests, and complying with regulatory requirements.

(f) Third-Party Contractual Compliance – Fulfilling obligations under agreements with

service providers, business partners, or affiliates.

(g) Intellectual Property and Content Management – Investigating and addressing

intellectual property claims, content moderation, and policy enforcement.

(h) Legal Defense and Risk Management – Establishing, exercising, or defending legal

claims, protecting our rights, and mitigating risks.

(i) Business Operations and Strategy – Conducting internal planning, reporting, financial

forecasting, and organizational management.

(j) Security, Fraud Prevention, and Risk Mitigation – Detecting, preventing, and

responding to fraudulent or unauthorized activities and ensuring data security.

(k) User Research and Feedback – Conducting surveys, usability testing, and other

research to improve our services.

3. DATA RETENTION PERIOD

3.1. The retention period for each category of personal information depends on the purpose of

collection, applicable legal requirements, and our legitimate business interests.

(a) Account Data – Retained for as long as your account remains active or as necessary to

provide our services. After account deletion, we may retain limited data for a

reasonable period to comply with legal obligations, enforce agreements, or resolve

disputes.

(b) Payment Data – Retained as required by financial regulations, including tax,

accounting, and anti-money laundering laws, typically for a period of 5 to 10 years.

and analytics. If anonymized, this data may be retained indefinitely for statistical and

research purposes.

4. YOUR RIGHTS AND CHOICES

4.1. Your Rights Under the CCPA and CPRA. As a California resident, you have specific

rights regarding your personal information under the California Consumer Privacy Act and

the California Privacy Rights Act:

(a) Right to Know – You may request information about the personal data we collect,

use, and disclose, including the categories of data and purposes for processing.

(b) Right to Request Deletion – You may request the deletion of your personal

information, subject to legal exceptions (e.g., regulatory compliance, fraud

prevention).

data is sold or shared for cross-context behavioral advertising.

(d) Right to Correct – You may request the correction of inaccurate personal information

we hold about you.

(e) Right to Limit the Use and Disclosure of Sensitive Personal Information – You

may restrict the use of sensitive data (e.g., financial information) to only essential

purposes.

4.2. How to Exercise Your Rights? To exercise any of these rights, you may contact us at

[email protected]. We will process your request in accordance with applicable laws and

within the legally required timeframes. For further details, please refer to the Privacy Policy.

5. HOW TO OPT-OUT OF SALE OR SHARING

5.1. While we do not sell personal information as defined by the CCPA, we may share your

personal data with third parties for purposes such as cross-context behavioral advertising.

You can opt out of such sharing at any time by using the Opt-Out Choices links above or

by contacting us at [email protected]

5.2. If you choose to opt out, we will respect your preference in all applicable circumstances.

However, you may need to renew your opt-out settings if you clear your cookies, use a

different device, or switch browsers.

5.3. Opting out of the sale or sharing of your personal information may result in reduced

personalization of certain services or functionalities that rely on data-sharing. Some

features may not function as intended.

6. UPDATES TO THIS NOTICE

6.1. Every 12 month we shall review these Privacy Notice and we may update this California

Notice at Collection from time to time to reflect changes in our practices, legal requirements,

or other operational reasons.

6.2. Notification of Material Changes. If we make material changes to this Notice, we will provide

you with clear and prominent notice, as required by applicable law. This may include:

(a) Displaying a notice on our website

(b) Sending an email notification

6.3. For the latest updates, we encourage you to review this Notice periodically.

7. CONTACT US

7.1. For any questions or concerns about this Notice, contact our Data Protection Officer any one

of these ways:

Email: [email protected]

2. NOTICE ON GDPR COMPLIANCE

- ANNEX 2 -

This GDPR Compliance Notice is provided to residents of the European Economic Area in accordance

with the General Data Protection Regulation (Regulation (EU) 2016/679 of April 27, 2016). It

outlines the categories of personal data we collect; the purposes for which personal data is processed;

the safeguards in place for international data transfer

1. GENERAL TERMS AND SCOPE

1.1. This EEA Data Protection Notice is provided to residents of the European Economic Area

(EEA) in accordance with the General Data Protection Regulation (Regulation (EU)

2016/679 of April 27, 2016) (GDPR).

1.2. This Notice forms an integral part of our Privacy Notice and applies exclusively to individuals

residing within the EEA. It does not extend to individuals outside the EEA, including those in

other countries or regions unless otherwise is required by law or specified in this Annex.

1.3. In case of any inconsistency between this EEA Data Protection Notice and our general

Privacy Notice, the provisions of this Notice shall govern for EEA residents.

1.4. We may revise this Notice periodically to reflect changes in legal requirements, regulatory

updates, or operational adjustments. When material changes occur, we will provide a clear

and prominent notice, which may include:

(a) A notification on our website

(b) An email update

1.5. For the latest version, we encourage you to review this Notice regularly.

2. CROSS-BORDER TRANSFERS OF PERSONAL DATA

2.1. In accordance with Article 49(1)(a) of the General Data Protection Regulation

(Regulation (EU) 2016/679) (GDPR), we may transfer your personal data to partners

located outside the European Economic Area (EEA). These countries may not provide the

same level of data protection as your country of residence. To ensure compliance with GDPR,

we implement the following safeguards:

(a) Standard Contractual Clauses (SCCs) – We establish legally binding agreements

with our partners using EU-approved Standard Contractual Clauses (SCCs). These

clauses provide a lawful basis for data transfers and ensure appropriate protection.

(b) Third-Party GDPR Compliance – We only transfer personal data to third parties

that demonstrate adherence to GDPR standards, including the implementation of

appropriate security measures and privacy safeguards.

3. RISKS ASSOCIATED WITH CROSS-BORDER DATA TRANSFERS

3.1. While we and our third-party partners implement reasonable and necessary measures to

protect your personal data from unauthorized access, we must inform you of the potential risks

associated with transferring your data to jurisdictions outside the European Economic Area

(EEA), in compliance with Article 49(1)(a) of the General Data Protection Regulation

(Regulation (EU) 2016/679) (GDPR).

3.2. By consenting to the processing of your personal data under this Privacy Policy, you explicitly

acknowledge and accept the possible risks of such transfers, including:

(a) Different Regulatory Standards – Non-EEA jurisdictions may have data protection

laws that differ from GDPR. However, we implement safeguards to ensure that data

subjects receive an equivalent level of protection.

(b) Access by Government Authorities – Local government agencies may request access

to your personal data under applicable local laws. We limit disclosures to the extent

legally permissible and challenge disproportionate requests where possible.

parties may attempt to access your personal data. We take all necessary precautions to

prevent such attempts and protect your data from breaches.

4. SAFEGUARDS FOR INTERNATIONAL TRANSFERS

4.1. To ensure the security and integrity of your personal data during international transfers, we

implement the following safeguards:

(a) Standard Contractual Clauses (SCCs) – We use EU-approved SCCs to establish a legal

framework for compliant data transfers.

(b) Risk Assessments – We evaluate potential risks associated with each transfer to ensure

compliance with GDPR.

secure access controls to protect your personal data.

(d) Additional Compliance Policies – We establish internal policies and procedures to

prevent unauthorized access and ensure that third parties meet GDPR requirements.

5. EXPLICIT CONSENT FOR CROSS-BORDER TRANSFERS

5.1. By agreeing to this Privacy Policy, you explicitly consent to the transfer of your personal

data to jurisdictions outside the EEA, including those that may not provide the same level of

protection as GDPR.

5.2. We ensure that:

(a) Your rights as a data subject are upheld.

(b) All transfers occur with the necessary legal and technical safeguards in place.

6. DATA STORAGE AND TRANSFER PRACTICES OUTSIDE THE EEA

6.1. If your personal data is stored or transferred outside the EEA, we comply with GDPR by

implementing:

(a) Standard Contractual Clauses (SCCs) – Establishing a legally binding framework for

secure and GDPR-compliant data transfers.

(b) Technical and Organizational Security Measures – Protecting data through encryption,

access restrictions, periodic security audits, and other risk-mitigation practices.

data protection obligations.

7. CONTACT US

7.2. For any questions or concerns about this Notice, contact our Data Protection Officer any one

of these ways:

Email: [email protected]