KETO CYCLE COMMITMENT TO PRIVACY
Kilo Group LTD, its subsidiaries and affiliates are committed to managing personal information in accordance with the Lithuanian Privacy Principles under the Privacy Act 1988 (Cth), the General Data Protection Regulation (EU) 2016/679 (GDPR) and in accordance with other applicable privacy laws.
ABOUT KETO CYCLE
Keto Cycle is an online ness and wellness program.
Keto Cycle offers a range of services, including online workout and nutrition tutorials.
WHAT INFORMATION DOES KETO CYCLE COLLECT ABOUT YOU?
Members and prospective members
When you enquire about our services or when you subscribe or become a member of Keto Cycle , a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions.
We may also collect relevant information from third party sources such as [LinkedIn] and other professional websites.
Keto Cycle may collect personal information about other individuals who are not members of Keto Cycle . This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to Keto Cycle ; and other individuals who interact with Keto Cycle on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Keto Cycle . Generally, it would include name, contact details, and information regarding our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
You can always decline to give Keto Cycle any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
Your sensitive information
Keto Cycle may collect and process your sensitive information or special category data, such as your health information, generally with your express consent and only as reasonably necessary in order for us to provide our services to you. We may also collect such information about you in an emergency or otherwise with your consent or in accordance with applicable laws.
Visitors to our websites
The way in which we handle the personal information of visitors to our websites is discussed below.
What happens if you don’t provide your personal information?
You can always decline to give Keto Cycle any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested or we may not be able to do business with you effectively. If you have any concerns about personal information we have requested, please let us know.
HOW AND WHY DOES KETO CYCLE COLLECT AND USE YOUR PERSONAL INFORMATION?
Keto Cycle collects personal information reasonably necessary to carry out our business, to assess and manage our members' needs, and provide our services to you. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing member relationships.
The purposes for which Keto Cycle usually collects and uses personal information depends on the nature of your interaction with us, but may include:
third party suppliers and contractors who assist us to operate our business.
our affiliated and related companies;
to improve the relevance of marketing messages we may send you (which you can opt out of as explained below).
to bring to your attention (in person or by post, email or telephone) information about additional services offered by us and/or our [global affiliates], which may be of interest to you, unless you indicate at any time that you do not wish us to do so; and
if instructed to do so by you or where you give us your consent to the use and/or processing involved;
to share information with relevant third parties in the context of a sale or potential sale of a relevant part of our business, subject always to confidentiality obligations;
to check your instructions to us, to analyse, assess and improve our services to members, as well as for training and quality purposes, we may monitor, record and analyse any communications between you and us, including phone calls;
to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
to comply with any requirement of any applicable statute, regulation, rule and/or good practice, whether originating from [Lithuanian] or elsewhere;
to follow up with you after you request information to see if we can provide any further assistance (for example if you enquire about a membership package);
to confirm your identity and carry out background checks, including as part of our checks in relation to your application to become a subscriber member;
for our reasonable commercial purposes (including quality control and administration and assisting us to develop new and improved products and services);
responding to enquires and complaints.
recruitment processes; and
informing you of our activities, events, facilities and services;
researching, developing and expanding our facilities and services;
managing, planning, advertising and administering programs, events, competitions and performances;
responding to requests for information and other general inquiries;
to record statistical data for marketing analysis from members;
to obtain opinions or comments about products and/or services from members;
to provide information about products, services and/or special offers to members;
to fulfil obligations under a membership agreement and/or any other contract you may have with us;
any additional personal information you provide to us, or authorise us to collect, as part of your interaction or membership with Keto Cycle .
any additional information relating to you that you provide to us directly through our websites or by other means such as over the phone, via email or in person; information you provide to us via voluntary members feedback or engagement surveys;
your login details and passwords which you use to access your account with us as well as your online interactions with us;details of the products and services (such as membership options) you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
your ness and nutrition statistics which you provide to us;
In addition, some of your personal information may be used for other business purposes. Examples of the types of uses are set out below:
Keto Cycle generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
Keto Cycle also collects and uses personal information for market research purposes and to innovate our delivery of products and services. We have a legitimate interest in using your information in the ways listed above. In some cases it will be lawful for us to collect and use your personal information, for example where it is necessary as part of our, or a third party’s, statutory or public functions or because the law permits or requires us to.
HOW DOES KETO CYCLE INTERACT WITH YOU VIA THE INTERNET?
Keto Cycle websites may contain links to third-party websites. Keto Cycle is not responsible for the content or privacy practices of websites that are linked to our website.
Keto Cycle cookies policy
What is a cookie?
While the cookie may identify your computer, it should not identify you unless you are registered with our website (for example, because you are a member and subscribe to our website) or logged in using your social media profile. In that case, the cookie will be linked to your profile so that we can identify you and provide more relevant content.
The types of cookies we use
Specifically, we use the following cookies:
Strictly necessary cookies: are required for the operation of our website, such as cookies that enable you to log into secure areas of our website (for example, our membership portal).
Analytical/performance cookies: allow us to count the number of users and see how users move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Targeting cookies: these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information, subject to your choices and preferences, to make our website and any advertising displayed on it more relevant to your interests.
Third party/sharing cookies: are cookies that are set by a domain other than the one being visited by you. If you visit our website and a separate company sets a cookie through that website this is a third party cookie. To try to bring you offers and advertisements that are of interest to you, we have relationships with third party companies including [Google, Adobe Analytics, Facebook, LinkedIn] (Third Party Providers) that allow them to place cookies on our websites.
These Third Party Providers may:
use Third Party Cookies, web beacons, and other storage technologies to collect or receive information from our Websites and elsewhere on the internet;
compare de-identified information from us with information collected elsewhere on the internet; and
use that information to provide measurement services and target ads to you.
How long cookies will be stored on your device
Session cookies are temporary. They allow website operators to link the actions of a user during a browser session, the time period between a user opening a browser window and closing it. Once closed, the cookies are deleted. Persistent cookies remain on a user’s device for the period of time specified in the cookie.
How you can manage your cookies
CAN YOU DEAL WITH KETO CYCLE ANONYMOUSLY?
Keto Cycle will provide you with the opportunity of remaining anonymous or using a pseudonym in your dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is not practicable for Keto Cycle to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.
HOW DOES KETO CYCLE HOLD INFORMATION?
Keto Cycle stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in [Lithuanian and the United States). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
Keto Cycle maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY KETO CYCLE
legal and regulatory requirements and guidance;
limitation periods that apply in respect of taking legal action;
our ability to defend ourselves against legal claims and complaints;
good practice; and
the operational requirements of our business.
We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.
DOES KETO CYCLE USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
Keto Cycle may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable privacy laws.
This means under certain privacy laws we do not always need your consent to send you marketing communications such as our member newsletter. However, where consent is required under applicable privacy laws, we will ask for this consent separately and clearly. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message.
If you opt-out of receiving marketing material from us, Keto Cycle may still contact you in relation to its ongoing relationship with you.
HOW DOES KETO CYCLE USE AND DISCLOSE PERSONAL INFORMATION?
The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers (including a personal trainer who is a contractor) where this is relevant to our services.
For customers and participants
If you are a customer or participant in an event, we may disclose your personal information to venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.
Disclosure to contractors and other service providers
Keto Cycle may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
Personal information may also be shared between related and affiliated companies of Keto Cycle , located in [Lithuanian and overseas].
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Use and disclosure for administration and management
Keto Cycle will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
administering billing and payments and debt recovery;
planning, managing, monitoring and evaluating our services;
quality improvement activities;
statistical analysis and reporting;
training staff, contractors and other workers;
risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
responding to enquiries and complaints regarding our services;
obtaining advice from consultants and other professional advisers; and
responding to subpoenas and other legal orders and obligations.
Other uses and disclosures
DOES KETO CYCLE DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?
Keto Cycle is a global organisation and works with members, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients including service providers who may handle, process or store your personal information on our behalf.
The recipients of such information may be located in USA or Lithuanian.
Entities, which are related entities of Keto Cycle , or are otherwise affiliated with Keto Cycle , have operations in USA and Lithuanian
We generally collect personal information about you in Lithuanian or the jurisdiction in which the Keto Cycle affiliate you are dealing with is located.
It is likely that your personal information will be transferred outside of the jurisdiction it was collected. We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the European Economic Area. The EU standard contractual clauses are available here.
There are circumstances where we may disclose your personal information to an overseas recipient. For example, you have provided your consent or we are otherwise permitted to do so under the Lithuanian Privacy Principles or other relevant laws.
RESIDENTS IN THE EUROPEAN ECONOMIC AREA
We have described the purposes for which we may use your personal information. If the GDPR applies to you, we are permitted to process your personal information in this way, in compliance with the GDPR, by relying on one or more of the following lawful grounds:
you have explicitly agreed to us processing your information for a specific reason;
the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
the processing is necessary for compliance with a legal obligation we have; or
the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
to prevent fraud;
to protect our business interests;
to ensure that complaints are investigated; to evaluate, develop or improve our products; or
to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
If the GDPR applies to you, you have the following additional and specific rights in relation to your personal information (where applicable):
Access: you have the right to request a copy of any personal information we hold about you. Any request for access to or a copy of your personal information must in writing and we will endeavour to respond within a reasonable period and in any event within one month (in compliance with the GDPR).
Rectification: you have the right to the rectification of your personal data, if you consider that it is inaccurate.
Deletion: you have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such personal information in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction: you have the right to erasure of your personal information, if you consider that we do not have the right to hold it.
Portability: you have the right to ask us to transfer a copy of your personal information to you or to another service provider or third party where technically feasible.
Objection: you have the right to object to your personal information being processed for a particular purpose or to request that we stop using your information.
Complaint: If you are unhappy with our treatment of your personal information, and you have contacted us as set out below, you have the right to lodge a complaint with thelocal data protection authority.
If you have consented to our processing of your personal information, you have the right to withdraw, at any time, any consent that you have previously given to us for use of your personal information. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
To make a request to exercise any of these rights (where applicable) in relation to your personal information, please contact us using the contact details below.
HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You are entitled to access your personal information held by Keto Cycle on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Lithuanian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps, which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that Keto Cycle may have breached the Lithuanian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Lithuanian Information Commissioner.
If you are outside of Lithuanian you may wish to take your complaint up with the local data protection authority in your jurisdiction.
HOW CAN YOU CONTACT KETO CYCLE ?
The contact details for Keto Cycle are:
Keto Cycle Privacy Officer
Antakalnio 17, Vilnius, Lithuania