Privacy Policy
Introduction
2. Joint Data Controllers
The persons jointly responsible for the processing of personal data described in this Privacy Policy are:
Daniel Söderlund
Co-founder of the Neutrien project
and
Leo Koivikko
Co-founder of the Neutrien project
Country of establishment: Finland
Privacy email: contact@neutrien.io
Daniel Söderlund and Leo Koivikko act as joint data controllers where they jointly determine the purposes and means of processing personal data through the Neutrien website, surveys, launch registrations, interviews, and related communications.
The founders have agreed on their respective responsibilities for complying with applicable data-protection law. For practical purposes, privacy requests and questions may be sent to the shared contact address above.
You may exercise your data-protection rights against either joint controller, regardless of the internal division of responsibilities between them.
Neutrien is currently a project name and is not a separate incorporated legal entity.
3. Personal Data We Collect
The personal data we collect depends on how you interact with us.
3.1 Information You Provide Directly
We may collect:
your email address;
your name or preferred name;
your age or age range;
your country or general location;
your preferred language;
your responses to surveys and questionnaires;
your dietary preferences;
your food preferences and dislikes;
information about allergies or intolerances;
nutrition-related goals;
meal-planning habits;
information about exercise, lifestyle, or daily routines;
your feedback about proposed features and pricing;
your interest in participating in research;
your availability for interviews;
information you provide during interviews or usability tests;
recordings, transcripts, notes, or screenshots from research sessions where you have been informed and any required consent has been obtained;
correspondence you send to us;
your communication and marketing preferences; and
any other information you voluntarily submit through an open-text field, email, survey, or interview.
Please do not provide personal information that is not reasonably necessary for the purpose of the survey, form, or communication.
You should not provide personal data about another person unless you have their permission and are legally permitted to do so.
3.2 Health-Related and Other Sensitive Information
Some survey or interview questions may concern matters such as:
allergies and food intolerances;
dietary restrictions;
nutritional deficiencies;
medical diets;
body measurements;
weight-related goals;
physical activity;
health conditions;
medication;
pregnancy;
eating habits; or
other information that may reveal details about your physical or mental health.
Depending on the context, this information may constitute health data or another special category of personal data under applicable data-protection law.
We will only request or process such information where it is reasonably necessary for the stated research purpose and where we have an appropriate legal basis. Where required, we will ask for your explicit consent before collecting or using health-related personal data.
Participation is voluntary. You do not need to provide health-related information unless the relevant form clearly identifies it as necessary for that specific activity.
You may withdraw your explicit consent at any time. Withdrawal does not affect processing that occurred lawfully before the withdrawal.
Where possible, we will analyse health-related survey information in aggregated or de-identified form.
The pre-launch website is not a healthcare service, and information submitted through a survey or interview is not monitored for medical emergencies.
4. Information Collected Automatically
When you visit the Website, we or our service providers may automatically collect certain technical information, including: IP address; browser type and version; device type; operating system; device identifiers; approximate location derived from an IP address; referring website or campaign; pages viewed; buttons or links selected; time and date of access; time spent on pages; language settings; error logs; cookie identifiers; and other technical and usage information. We may collect this information through server logs, cookies, pixels, analytics tools, and similar technologies. See Section 12 for more information about cookies and similar technologies.
5. Sources of Personal Data
We generally collect personal data: directly from you; automatically from your browser or device; from survey, scheduling, email, analytics, hosting, or video-conferencing providers used to support the Website; from referral links or campaign parameters; and from publicly available sources where necessary to respond to a business or media enquiry. We do not currently purchase consumer data from data brokers for the purposes described in this Privacy Policy.
6. Why We Process Personal Data
We process personal data for the following purposes.
6.1 Operating and Securing the Website
We use technical and usage information to: provide and operate the Website; display content correctly; maintain website functionality; diagnose errors; prevent fraud, spam, abuse, and security incidents; protect our systems and users; and keep records of consent and privacy preferences. Legal basis: Our legitimate interests in operating, maintaining, and protecting the Website, and compliance with legal obligations where applicable.
6.2 Administering Surveys
We use survey information to: administer surveys; record and analyse responses; understand prospective users’ needs and behaviour; evaluate interest in proposed Neutrien features; improve product concepts, designs, pricing, and communications; identify general trends; create aggregated or anonymised research findings; and determine whether a participant may be suitable for a follow-up interview. Legal basis: Your consent where the survey is optional and consent is the appropriate basis; our legitimate interests in conducting pre-launch product and market research where those interests are not overridden by your rights; and explicit consent where required for health-related or other special-category data.
6.3 Providing Launch Benefits and Discounts
We use your email address and related registration information to: record your eligibility for a launch benefit; prevent duplicate or fraudulent registrations; send confirmation of your registration; deliver a discount code or redemption instructions; notify you when the benefit becomes available; administer the benefit under its applicable terms; and answer questions concerning the benefit. Legal basis: Taking steps at your request before entering into a possible contract, performing an agreement concerning the requested benefit, and our legitimate interests in administering and protecting the promotion. Messages strictly necessary to confirm or deliver a benefit you requested are service or administrative communications. They are not treated as consent to receive unrelated marketing.
6.4 Sending Marketing Communications
Where you have separately chosen to receive them, we may send: Neutrien launch announcements; product updates; newsletters; promotional offers; feature announcements; research opportunities; and other marketing communications. Legal basis: Your consent. You may withdraw your marketing consent at any time by selecting the unsubscribe link in an email or contacting us at [PRIVACY EMAIL]. Withdrawing consent does not affect processing that occurred lawfully before withdrawal.
6.5 Recruiting Research Participants
Where you have volunteered to be contacted about research, we may use your contact details and relevant survey answers to: assess suitability for a research project; invite you to an interview or usability test; schedule and administer a research session; communicate instructions; send reminders; and arrange any agreed incentive or compensation. Legal basis: Your consent, taking steps at your request in connection with research participation, and our legitimate interests in conducting product research where appropriate. Agreeing to be contacted does not guarantee selection for an interview.
6.6 Conducting Interviews and Usability Research
We may process information shared during an interview or usability test to: understand user needs and experiences; test proposed features, interfaces, or messages; identify usability problems; improve the planned application; prepare internal notes, summaries, and research reports; and create aggregated or anonymised insights. Where we wish to make an audio recording, video recording, screen recording, or transcript, we will inform you beforehand. We will obtain consent where required. Legal basis: Your consent; explicit consent where sensitive health information is intentionally collected; and our legitimate interests in developing and improving Neutrien where appropriate.
6.7 Responding to Enquiries
We use contact information and correspondence to: answer questions; handle complaints; respond to privacy requests; provide support; and maintain necessary records of the communication. Legal basis: Our legitimate interests in communicating with users and protecting our legal interests, taking steps at your request, and compliance with legal obligations.
6.8 Analytics and Website Improvement
Where permitted, we use website usage information to: understand how visitors find and use the Website; measure campaign and page performance; identify technical problems; evaluate website design and content; and improve the user experience. Where analytics technologies are non-essential and require consent, they will only be activated after you provide the required consent. Legal basis: Your consent for non-essential analytics cookies or similar technologies, and our legitimate interests for strictly necessary, privacy-preserving, or aggregated website measurements where permitted by law.
6.9 Establishing, Exercising, or Defending Legal Claims
We may retain and use relevant information to: establish or defend legal rights; investigate suspected breaches of our Terms; respond to lawful requests; prevent fraud or misuse; and comply with legal and regulatory requirements. Legal basis: Compliance with legal obligations and our legitimate interests in protecting our business and legal rights.
7. When Providing Data Is Required
Providing information through the pre-launch Website is generally voluntary. However, certain information may be necessary for a particular request. For example: an email address is required to record or deliver an email-based launch benefit; contact information may be required to arrange an interview; particular survey answers may be required to complete a survey; and technical information may be necessary for the Website to function securely. Where providing information is optional, we aim to indicate this on the relevant form. If you do not provide information identified as required, we may be unable to process the submission, provide the requested benefit, or contact you for an interview.
8. Legitimate Interests
Where we rely on legitimate interests, those interests may include: developing a product that reflects prospective users’ needs; conducting market and product research; understanding website performance; administering requested promotions; preventing fraud and duplicate registrations; maintaining network and information security; protecting Neutrien’s legal rights; responding to enquiries; and managing and improving our business. Before relying on legitimate interests, we consider whether the processing is necessary and whether your rights and interests override ours. You may have the right to object to processing based on legitimate interests. See Section 15. We do not rely on legitimate interests as a substitute for consent where consent is required by law, including for certain electronic marketing, non-essential cookies, or the intentional processing of special-category data.
9. How We Share Personal Data
We do not sell your personal data. We may share personal data with the following categories of recipients where necessary.
9.1 Website and Hosting Providers
Providers that host, deliver, maintain, secure, or support the Website and its databases. Current provider or providers: Framer
9.2 Survey and Form Providers
Providers used to create forms, collect survey responses, or manage registrations. Current provider or providers: Tally
9.3 Email and Customer Communication Providers
Providers used to send confirmations, discount information, launch announcements, newsletters, or other communications. Current provider or providers: Google
9.4 Scheduling, Interview, and Research Providers
Providers used to schedule interviews, conduct video calls, record sessions where authorised, transcribe interviews, or organise research.
9.5 Analytics and Cookie Providers
Providers used to understand website usage, subject to applicable consent requirements.
9.6 Professional Advisers
Lawyers, accountants, auditors, insurers, consultants, and other professional advisers where reasonably necessary. 9.7 Authorities and Legal Recipients Courts, regulators, law-enforcement bodies, public authorities, and other parties where disclosure is required by law or reasonably necessary to protect legal rights, safety, and security.
9.8 Business Transactions
A prospective buyer, investor, financing party, or successor may receive relevant information as part of a merger, financing, restructuring, acquisition, sale, or transfer of some or all of the Neutrien business. Where appropriate, we require recipients and service providers to protect personal data, process it only for authorised purposes, and comply with applicable data-protection law.
10. International Data Transfers
Some service providers may process personal data outside Finland, the European Economic Area, or your country of residence. Where personal data is transferred outside the EEA to a country that has not been recognised as providing an adequate level of protection, we will use an appropriate transfer mechanism where required, such as: European Commission standard contractual clauses; an applicable adequacy decision; binding corporate rules; or another legally recognised safeguard. Where appropriate, we will also assess whether supplementary technical, contractual, or organisational safeguards are required. You may contact us at [PRIVACY EMAIL] to request further information about the safeguards used for relevant international transfers.
11. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including legal, security, accounting, and dispute-resolution requirements. Unless a longer or shorter period is justified, we intend to apply the following retention periods:
11.1 Survey Responses
Identifiable survey responses will be retained for up to 6 months after collection, unless you withdraw consent earlier and no other legal ground permits continued retention. Aggregated or effectively anonymised research information may be retained indefinitely because it no longer identifies an individual.
11.2 Launch-List and Benefit
Registrations Email addresses and records needed to administer a requested launch benefit will be retained until: the benefit has been delivered and the applicable redemption period has ended; the Neutrien application or promotion is cancelled
11.3 Marketing Information
Marketing contact information will be retained until you withdraw consent or until we determine that the information is no longer active or necessary. We may retain a minimal suppression record after you unsubscribe so that we can respect your request and avoid adding you back to a marketing list accidentally.
11.4 Interview Recruitment
Information Information about potential interview participants who are not selected will generally be deleted within 6 months, unless the person has consented to being considered for future research.
11.5 Interview
Recordings and Transcripts Interview recordings will generally be deleted within 90 days after the research has been analysed. Interview transcripts and identifiable notes will generally be retained for up to 12 months, after which they will be deleted or anonymised. The specific retention period may also be communicated before an interview.
11.6 Correspondence and Privacy Requests
General correspondence may be retained for up to 24 months after the matter is closed. Records concerning legal claims, consent, objections, or data-subject requests may be retained for longer where necessary to demonstrate compliance or protect legal rights.
11.7 Technical and Security Logs
Server and security logs will generally be retained for 90 days, unless a longer period is necessary to investigate a security incident or suspected misuse. We periodically review retained information and delete or anonymise information that is no longer needed.
12. Cookies and Similar Technologies
The Website may use cookies, local storage, pixels, scripts, and similar technologies.
12.1 Strictly Necessary Technologies
These technologies are required for functions such as: website delivery; security; fraud prevention; load balancing; saving privacy choices; and submitting forms. Where permitted by law, strictly necessary technologies may be used without consent because the Website cannot operate properly without them.
12.2 Analytics Technologies
Analytics technologies help us understand matters such as page visits, referral sources, visitor interactions, and technical errors. Where these technologies are not strictly necessary, we will request consent before using them where required by law.
12.3 Marketing Technologies
We may use marketing or advertising technologies in the future to measure campaigns or deliver relevant advertising. Such technologies will not be activated before the required consent has been obtained.
12.4 Managing Your Choices
You can manage non-essential cookie choices through our cookie banner or cookie settings tool, where available. You can also restrict cookies using your browser settings. Blocking certain technologies may affect Website functionality. A separate Cookie Policy or cookie-settings panel may provide further details about each technology, its provider, purpose, and duration.
13. Automated Decision-Making and Profiling
We do not currently use personal data collected through the pre-launch Website to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals. We may use survey answers to group participants according to broad characteristics, interests, or research criteria. For example, we may identify respondents who are interested in particular nutrition features or who may be suitable for an interview. This form of research segmentation does not determine access to essential services and is not intended to produce legal or similarly significant effects. If this changes, we will update this Privacy Policy and provide any information and safeguards required by law.
14. Data Security
We use appropriate technical and organisational measures designed to protect personal data against: unauthorised access; accidental loss; unlawful disclosure; alteration; destruction; and misuse. Measures may include: access controls; authentication protections; encryption in transit; service-provider assessments; restricted internal access; data minimisation; backups; monitoring; and procedures for handling security incidents. No website, transmission method, or storage system is completely secure. We cannot guarantee absolute security, but we will take reasonable steps to protect the personal data under our control. Where required by law, we will notify the relevant supervisory authority and affected individuals of a personal-data breach.
15. Your Data-Protection Rights
Depending on applicable law and the circumstances, you may have the following rights.
15.1 Right of Access
You may request confirmation of whether we process your personal data and request a copy of that data.
15.2 Right to Rectification
You may ask us to correct inaccurate information or complete incomplete information.
15.3 Right to Erasure
You may ask us to delete personal data where there is no longer a lawful reason to retain it. This right is not absolute. We may retain information where processing is required by law or necessary for purposes such as legal claims.
15.4 Right to Restriction
You may ask us to restrict processing in certain circumstances, including while the accuracy or lawfulness of processing is being assessed.
15.5 Right to Data Portability
Where processing is based on consent or contract and carried out by automated means, you may have the right to receive personal data you provided in a structured, commonly used, machine-readable format and transmit it to another controller.
15.6 Right to Object
You may object to processing based on legitimate interests where your particular situation justifies the objection. You have the right to object at any time to processing for direct-marketing purposes. If you object to direct marketing, we will stop using your personal data for that purpose.
15.7 Right to Withdraw Consent
Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
15.8 Rights Relating to Automated Decisions
Where applicable, you may have rights concerning decisions based solely on automated processing that produce legal or similarly significant effects. As explained above, we do not currently carry out this type of automated decision-making through the pre-launch Website.
15.9 Right to Complain
You may lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement. If Neutrien is established in Finland, the relevant authority is: Office of the Data Protection Ombudsman Website: https://tietosuoja.fi/en/frontpage We encourage you to contact us first so that we have an opportunity to address your concern, but you are not required to do so before contacting a supervisory authority.
16. Exercising Your Rights
To exercise a privacy right, contact: Email: contact@neutrien.io Please describe your request clearly and identify the email address or other information connected with your submission. We may request additional information where reasonably necessary to confirm your identity. We will not request more information than necessary for verification. We will normally respond within one month of receiving a valid request. Where permitted by law, this period may be extended for a further two months if the request is complex or numerous. We will inform you if an extension is required. Requests are generally free of charge. We may charge a reasonable fee or decline to act where a request is manifestly unfounded or excessive, as permitted by law.
17. Children’s Privacy
The pre-launch Website, surveys, and research activities are not directed to children under 16 years old. We do not knowingly collect personal data directly from children under 16 without the involvement or authorisation of a parent or legal guardian where required by law. If you believe a child has provided personal data to us contrary to this section, contact us at contact@neutrien.io. We will investigate and take appropriate action, which may include deleting the information. We may apply a higher minimum age to particular surveys, interviews, promotions, or future services.
18. Third-Party Websites and Services
The Website may contain links to third-party websites or services. Those third parties act under their own privacy policies and may independently determine how they use personal data. This Privacy Policy does not govern third-party services that are not controlled by Neutrien. We encourage you to review the privacy information of any third-party website or service before providing information to it.
19. Anonymised and Aggregated Information
We may convert personal data into aggregated or anonymised information that no longer identifies you. We may use and retain genuinely anonymised information for purposes such as: product development; statistical analysis; research; business planning; investor materials; presentations; and publication of general findings. We will take reasonable steps designed to prevent anonymised information from being used to re-identify an individual. Pseudonymised information remains personal data where it can be linked back to an individual using additional information, and we will continue to protect it accordingly.
20. Changes to This Privacy Policy
We may update this Privacy Policy to reflect: changes to our Website; new surveys or research activities; changes to service providers; the launch of the Neutrien application; changes to our processing practices; or legal or regulatory developments. The updated version will be posted on this page with a revised “Last updated” date. Where a change materially affects how we use information already collected, we will provide additional notice or request fresh consent where required by law.
21. Contact Us
Questions, concerns, complaints, and privacy requests may be directed to:
Daniel Söderlund and Leo Koivikko
Joint data controllers operating the Neutrien project
Country: Finland
Email: contact@neutrien.io
You may also direct a request to either founder individually. However, using the shared privacy email will usually allow us to respond more efficiently.
