Privacy Policy

The present Privacy Policy sets the principles which govern the processing of personal data carried out within the use of the website www.gut-more.com (“Gutmore”) and the subscription and provision of the services offered therein. This policy also implements a privacy management system that guarantees a high and adequate level of protection of the personal data processed by Gutmore within the development of its activities, in strict compliance with the applicable legislation. This Privacy Policy is governed by the provisions of applicable legislation on privacy and personal data protection, most specifically, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR"). Gutmore reserves the right to amend this Privacy Policy, when such amendment is necessary in view of the activities it undertakes and if required by the applicable legal framework. 

Data controller

The data controller is the person or legal entity that determines the objectives and the means employed in the processing of personal data it carries out, within its activities and is deemed the data controller of such data.
The identification details of the data controller with respect to the activities carried out through Gutmore are:
Name: Michaela Gruebler
Taxpayer number: 304598062;
E-mail address: michaela@gut-more.com

Principles governing personal data processing

The processing of personal data carried out by Gutmore is governed by the following principles:
• Lawfulness of processing of personal data, loyalty and transparency vis-à-vis the data subjects;
• Limitation of the purposes of processing, which must be specified, explicit and lawful;
• Adequacy and limitation of the personal data collected to what is strictly necessary, taking into consideration the purposes for which they were collected;
• Accuracy and updating of personal data, through the adoption of appropriate measures to this effect;
• Retention of personal data for no longer than necessary to fulfil the purposes for which they were collected; and
• Integrity and confidentiality of personal data, by adopting appropriate technical and organisational measures to ensure their safety.

What data do we collect and process?

Gutmore processes a variety of categories of personal data of data subjects, who are essentially the clients of Gutmore (or potential ones), collaborators, suppliers and/or business partners.
Within the scope of its activities, Gutmore processes the following types of personal data:
a) Identification data (such as name, contact details - email address, age, weight, taxpayer number);
b) Data related to the professional activity (e.g. profession);
c) Accounting and financial data (e.g. fees and expenses);
d) Personal information complied in the concept of special categories of data, such as health data (e.g., diseases or medicines) and data concerning sexual orientation;
e) Data regarding lifestyle, behavioural data with respect to nutrition, diet, smoking, alcohol consumption, sleep, job/daily activities, physical exercise; and
f) Cookies (only the ones necessary in order to establish a contract between devices and to be able to display browsing content suitable for the data subject, i.e., only functional cookies).

How and when do we collect data?

Gutmore collects your personal data directly in several circumstances, including:
(i) when you browse the Gutmore website (cookies);
(ii) when you submit a message using the “Contact us - Get in touch today” form on the website;
(iii) when you send us an email or any other written communication;
(iv) when you fill in the questionnaires envisaged by Gutmore holistic health consultancy services via Google forms or any other format, and the “Daily Diary”;
(v) when you complete the questionnaire after receiving the kit for gut analysis;
(vi) within all direct interactions held during our coaching sessions, and
(vii) in case of Talents Profile, when you fill the questionnaire or provide any other information by other means for that purpose.

For what purposes and on what basis is the data processed?

a) On the grounds of the execution of a contract and performance of contract obligations. Gutmore processes the necessary data for the management of the contractual relationship relating to the provision of consultancy and coaching services. This processing activity includes the collection and processing of
personal data with the aim of profiling the client according to his or her lifestyle, in order to provide a more personalised advice;
b) On the grounds of consent of the data subject. In order to provide our clients with Gutmore consultancy and coaching services, we will need to perform a personal analysis, which entails the collection and processing of personal data, behavioural data, preferences, special categories of data, such as health data, and data concerning sexual orientation. In addition, based on your consent Gutmore collects and processes cookies to elaborate statistics on the use of the website, and to pursue marketing purposes;
c) On the grounds of compliance with legal obligations. Gutmore processes the necessary data for activities related to the invoicing of fees for services provided, as well as their accounting, financial and tax processing in accordance with the applicable rules.

What are your data protection rights?

In accordance with the applicable legislation, data subjects have several rights regarding the processing of their personal data. In this sense, Gutmore undertakes to provide adequate conditions for the exercise of these rights by the data subjects.
Gutmore does not create unjustified obstacles to the exercise of rights by data subjects. However, to ensure the security of these data, Gutmore will request from those submitting requests for the exercise of rights, information that will enable the identity of the petitioner to be validated, reserving the right not to process such requests where the identification of the data subject is not possible.
Gutmore will respond to requests from data subjects within a period not exceeding 1 month, unless the complexity of the request or the volume justifies an extension for a period not exceeding 2 months. In such case, Gutmore will communicate such extension and its motives to the data subject within 15 days from the date of receipt of the request.
As data subject you have the following rights:
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a) Right to access
You are entitled to obtain confirmation as to whether, or not, data concerning you are being processed and, where appropriate, access to your personal data as well as other information required by law.
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b) Right to rectification
You have the right to request Gutmore to correct any inaccuracy on your personal data or complete any incomplete personal data, including by means of an additional declaration.
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c) Right to erasure
This is also known as ‘the right to be forgotten’. It gives you the right to request the erasure of your data without undue delay. Gutmore is therefore obliged to erasure such data, when:
(i) The personal data is no longer necessary for the purpose for which it was collected or processed;
(ii) There is withdrawal of consent for data processing (in cases where processing is based on consent) and there is no other ground for such processing.
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d) Right to restrict data processing
You have the right to request Gutmore to limit the processing of your data. The processing of your personal data is then frozen during the restriction. Gutmore will not use it further, it will only store your personal data for the establishment or exercise of a right or for the defence of legal claims.
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e) Right to object
In cases of processing based on legitimate interest, you have the right to object at any time, provided that the processing relates to your personal data and your particular situation.
In such a context, Gutmore shall cease the processing of personal data, unless it provides compelling legitimate reasons for such processing which override the freedom, interests and rights of the data subject, as well for the establishment or exercise of a right or for the defence of legal claims.
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f) Right to withdraw consent
Where data processing is based on the provision of consent, as data subject you have the right to, at any time, withdraw the consent previously granted.
It should be noted however that this right does not affect the lawfulness of the processing carried out based on the consent previously provided nor the further processing of the same data based on another legal ground.
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g) Right to portability
If applicable, you have the right to receive the personal data concerning you, which you have provided to Gutmore, in a structured, commonly used and machine-readable format. Additionally, you have the right to transmit those data to another data controller without hindrance from Gutmore.
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h) Right to complaint
You have the right to lodge a complaint with the competent supervisory authority, if you consider that the processing of your personal data infringes the
local laws and regulations. For your information, the relevant authorities – per countries of the EEA – where you can lodge a complaint is listed here: https://edpb.europa.eu/about-edpb/board/members_en.
Before lodging a complaint to the supervisory authority, we encourage you to contact Gutmore first.

With whom do we share your data?

The personal data processed by Gutmore may be shared with the following recipients:
• Entities to whom the data must be communicated by Gutmore as legally required (e.g., social security, tax authorities, local data protection authorities, etc.);
• Third parties (e.g., service providers / suppliers) in whom Gutmore relies for the pursuit of its activities, to the extent that the sharing of data is necessary for the execution of the services or supply concerned (e.g., IT service providers and service providers in this area, such as Godaddy, TLP-Navigator and Google, and/or translation companies) and subject to the execution of the required data processing agreements;
• Third parties that are entities related to the object of the advice and coaching provided by Gutmore to its clients (e.g., biome diagnostics), to the strict extent that such sharing is necessary within the scope of the provision of such consulting and coaching services.
In cooperation with service providers and other third parties, appropriate legal instruments are used to ensure that the personal data that is shared and processed in accordance with this policy and with data protection legislation, as well stored securely only for as long as necessary. These legal instruments may be data processing agreements, executed in accordance with Article 28 of the GDPR.

Recipients of the personal data and data retention periods

The personal data collected and processed by Gutmore will only be accessed by a limited number of recipients on a need-to-know basis or where required by law. The primary recipients will be Michaela Gruebler.
The data will be kept for the period necessary to fulfil the purposes for which they were collected.
Personal data processed by Gutmore shall be kept (i) for the duration of the contractual relationship established between the data subject and Gutmore, without detriment to additional conservation for the legal term applicable with respect to the conservation of financial and accounting information, and for as long as the rights and obligations arising thereunder may be legally enforceable; (ii) for the period for which the data subjects have consented to the processing (without detriment to the possible periodic renewal of the consent granted); and (iii) for as long as the purpose which determined the collection and subsequent processing of data continues or, alternatively, for such other period as may be required by law.

Data security

Gutmore is committed to the security and confidentiality of your data, having implemented appropriate and necessary technical and organisational measures to ensure such commitment.
Gutmore periodically monitors its systems, practices, and policies to ensure that your personal data is protected and to prevent unauthorised access to it.

Data Security