Privacy Policy
SMARTERNUTHUB
PRIVACY POLICY
Effective Date: November 30, 2025 | Applicable Worldwide
This Privacy Policy explains how Smarternuthub collects, uses, stores, discloses, and protects your personal information across every product, service, platform, and interaction. It applies worldwide and governs all data collected in connection with the Monthly Membership, Nutrition Tracking App, all eBooks and Digital Products, the Supplement Guide, YouTube and social media content, email correspondence, direct messages, and the private Community. Please read it in full before providing any personal information to Smarternuthub.
SECTION 1: WHO WE ARE & HOW TO CONTACT US
1.1 Smarternuthub is a nutrition education business operated from Queensland, Australia ("Smarternuthub," "we," "us," or "our"). We are the data controller and data processor in respect of all personal information collected in connection with our Services.
1.2 For all privacy-related enquiries, requests, or complaints, contact us at: hello@smarternuthub.com. We will acknowledge your enquiry within a reasonable timeframe and respond substantively within thirty (30) days, or within the timeframe required by applicable law in your jurisdiction, whichever is shorter.
1.3 This Privacy Policy must be read together with the Smarternuthub Terms of Service, Refund Policy, and Medical Disclaimer, each of which is incorporated by reference. Capitalised terms used but not defined in this Policy have the meanings given in the Terms of Service.
SECTION 2: DEFINITIONS
"GLP-1 Data" the subset of Health Data relating to GLP-1 receptor agonist medication use, including medication name, current dosage, injection day, and any related App settings or reminders.
"Health Data" personal information submitted to the App relating to an individual's physical health or body, including first name, date of birth, biological sex, height, current weight, goal weight, dietary preferences, activity levels, and GLP-1 Data.
"Personal Information" any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not, and whether recorded in material form or not. This includes, without limitation, name, email address, payment details, IP address, device identifiers, Health Data, and GLP-1 Data.
"Processing" any operation performed on Personal Information, including collection, recording, storage, use, disclosure, transfer, erasure, or destruction.
"Sensitive Information" a subset of Personal Information afforded heightened protection, including Health Data, GLP-1 Data, information about mental health, racial or ethnic origin, religious beliefs, and criminal record. Health Data and GLP-1 Data constitute Sensitive Information under Australian, European, and most other applicable privacy frameworks.
"Services" the full suite of Smarternuthub products and interactions as defined in the Terms of Service.
SECTION 3: INFORMATION WE COLLECT
3.1 Information You Provide Directly
We collect Personal Information that you provide directly to us through the following channels:
3.1.1 Account Registration: When you create a Smarternuthub account or activate a Membership or App subscription, we collect your name, email address, password, and payment method details (processed by our third-party payment processor — we do not store full card numbers).
3.1.2 Health Data (App): When you use the Nutrition Tracking App, you voluntarily submit Health Data including your first name, date of birth, biological sex, height, current weight, goal weight, dietary preferences, and activity levels. This data is used solely to generate personalised App nutritional targets and to provide App features.
3.1.3 GLP-1 Data (App): When you activate GLP-1 Settings within the App, you voluntarily submit GLP-1 Data including your medication name, current dosage, injection day, and injection reminder preferences. Sensitive Information is collected only with your explicit consent, for the sole purpose of personalising your App nutritional targets.
3.1.4 eBook & Lead Magnet Opt-Ins: When you download a free eBook, the Supplement Guide, or any free Digital Product, we collect your name and email address for the purpose of delivering the requested content and, where you have consented, for email marketing communications.
3.1.5 Paid eBook Purchase: When you purchase an eBook, we collect your name, email address, and payment details (via our payment processor).
3.1.6 Correspondence: When you contact us by email, direct message, or any other written channel, we collect the content of your communication and any Personal Information you choose to include, including any health information you voluntarily disclose.
3.1.7 Community Participation: When you participate in the private Smarternuthub Community, we collect your profile information and any content you post, including any health information you voluntarily disclose in posts, comments, or replies.
3.1.8 Public Platform Interactions: If you comment on Smarternuthub YouTube videos, Facebook posts, Instagram content, or LinkedIn posts, any information you include in those comments is public and collected by the relevant platform under its own privacy policy. Any information you voluntarily disclose publicly is not subject to any duty of confidentiality by Smarternuthub.
3.2 Information Collected Automatically
3.2.1 Technical Data: When you access the Smarternuthub website or App, we automatically collect technical information including your IP address, device type, operating system, browser type, and device identifiers.
3.2.2 Usage Data: We collect information about how you interact with the Services, including pages visited, features accessed, session duration, App login timestamps, content accessed within the Membership, and App usage patterns.
3.2.3 Cookies & Tracking Technologies: We use cookies, pixel tags, web beacons, and similar tracking technologies as described in Section 7 of this Policy.
3.2.4 Payment Transaction Data: Our payment processor retains transaction records including amounts charged, transaction dates, and billing identifiers. We retain records of Subscription Fees charged and confirmation of payment. We do not store full payment card numbers.
3.3 Information We Do Not Collect
3.3.1 We do not intentionally collect Personal Information from individuals under the age of 18. If we become aware that we have collected Personal Information from a minor without verifiable parental consent, we will take steps to delete that information promptly. If you believe a minor has submitted information to us, contact us at hello@smarternuthub.com.
3.3.2 We do not collect blood markers, clinical test results, or other biomedical data unless you voluntarily disclose such information in correspondence or Community posts.
SECTION 4: HOW WE USE YOUR INFORMATION
We use your Personal Information only for the purposes set out below. We do not use your Personal Information for any purpose incompatible with the purpose for which it was collected without your consent.
4.1 Providing the Services: To create and manage your account, process payments, provide access to the Membership, App, Digital Products, and Community, and deliver content you have purchased or requested.
4.2 App Personalisation: Health Data and GLP-1 Data are used exclusively to generate personalised nutritional targets, macronutrient allocations, and App features. They are not used for marketing, profiling, or any purpose other than App functionality.
4.3 GLP-1 Injection Reminders: Where you activate the injection reminder feature, your nominated injection day is used to send you email reminders on that day only. This data is not used for any other purpose.
4.4 Email Communications: We use your email address to send transactional communications (purchase confirmations, cancellation confirmations, subscription renewal notices, price change notices) and, where you have provided separate consent, marketing communications including newsletters, product updates, and promotional content.
4.5 Analytics & Service Improvement: We use usage data and technical data to understand how users interact with the Services, identify technical issues, and improve our products and content.
4.6 Legal Compliance & Enforcement: We use Personal Information where necessary to comply with applicable laws, respond to lawful requests from authorities, enforce our Terms of Service, Refund Policy, and other agreements, and protect our legal rights and interests, including in connection with chargeback disputes.
4.7 Chargeback & Fraud Prevention: In the event of a disputed payment or chargeback, we may use Personal Information — including account registration data, login records, IP address, device data, and content access logs — to demonstrate the validity of a charge to our payment processor, bank, or relevant authority. This use is described in detail in our Refund Policy.
4.8 Marketing (Testimonials & Success Stories): Where you share a success story, result, or testimonial in the Community or in correspondence, and subject to Section 9.3 of the Terms of Service, we may use that content for marketing and business improvement purposes.
SECTION 5: LEGAL BASES FOR PROCESSING
We process your Personal Information on the following legal bases, which vary depending on the nature of the data and the purpose of processing:
5.1 Contract Performance: Processing necessary to perform our contractual obligations to you — including providing Membership access, App functionality, processing payments, and delivering Digital Products — is conducted on the basis of contract performance.
5.2 Explicit Consent (Sensitive Information): The collection and processing of Health Data and GLP-1 Data is conducted on the basis of your explicit, freely given, informed, and specific consent, provided at the point of submission within the App. You may withdraw consent for Health Data and GLP-1 Data processing at any time by contacting us at hello@smarternuthub.com, noting that withdrawal of consent will limit or prevent your use of relevant App features.
5.3 Consent (Marketing): Marketing communications are sent only where you have provided separate, freely given consent. You may withdraw marketing consent at any time by using the unsubscribe link in any marketing email or by contacting us at hello@smarternuthub.com.
5.4 Legitimate Interests: We process certain Personal Information on the basis of our legitimate interests, including fraud prevention, chargeback defence, security, service improvement, and legal enforcement — where those interests are not overridden by your privacy rights. We have assessed that these legitimate interests are proportionate and do not cause undue risk to your rights.
5.5 Legal Obligation: We process Personal Information where required to comply with applicable laws, court orders, or lawful requests from regulatory or law enforcement authorities.
Note for EU/UK Users: Where the General Data Protection Regulation (EU) 2016/679 (GDPR) or UK GDPR applies to our processing of your Personal Information, the legal bases in this Section 5 constitute our lawful basis for processing under Article 6 and, for Sensitive Information, Article 9 of the GDPR. Your rights under the GDPR are set out in Section 11 of this Policy. GDPR rights cannot be contractually waived and Smarternuthub does not seek to do so.
SECTION 6: HEALTH DATA & GLP-1 DATA — SPECIFIC PROVISIONS
Health Data and GLP-1 Data are Sensitive Information and are afforded heightened protection. The provisions of this Section apply in addition to all other provisions of this Policy.
6.1 Collection Basis: Health Data and GLP-1 Data are collected only where you voluntarily submit that information within the App. Submission is entirely optional — however, certain App features (including personalised nutritional targets and GLP-1 Settings) cannot function without the relevant data.
6.2 Purpose Limitation: Health Data and GLP-1 Data are used exclusively for the purpose of providing and personalising App features. They are not used for marketing, advertising, profiling, or any commercial purpose beyond App functionality.
6.3 No Sale or Sharing: Health Data and GLP-1 Data are never sold, rented, or disclosed to any third party for commercial purposes. They are disclosed only to our hosting and infrastructure providers who process data on our behalf under contractual data processing agreements, and only to the extent necessary to operate the App.
6.4 Accuracy: You are responsible for ensuring the accuracy of Health Data and GLP-1 Data you submit. Smarternuthub accepts no responsibility for inaccurate App outputs arising from inaccurate data submission.
6.5 Security PIN: Where you activate the optional Security PIN feature, your PIN is not stored by Smarternuthub in recoverable form. It operates as a device-level access control only. Loss of your PIN may result in loss of locally cached App data.
6.6 Retention: Health Data and GLP-1 Data are retained for the duration of your active App Subscription. Upon cancellation, Health Data and GLP-1 Data are retained for a maximum of thirty (30) days from your final Billing Date, after which they are permanently deleted. You may request earlier deletion in accordance with Section 11.
6.7 Withdrawal of Consent: You may withdraw consent to the processing of Health Data and GLP-1 Data at any time by contacting hello@smarternuthub.com or by deleting your App account. Withdrawal of consent will result in deletion of that data and will disable the relevant App features. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
SECTION 7: COOKIES, PIXELS & TRACKING TECHNOLOGIES
7.1 Smarternuthub uses cookies, pixel tags, web beacons, and similar tracking technologies on its website and in its digital communications for the purposes described in this Section.
7.2 Types of Tracking We Use:
(a) Essential Cookies: Cookies necessary for the website and App to function, including session management, login authentication, and security. These cannot be disabled without impairing Service functionality.
(b) Analytics Cookies: Cookies and tools (including Google Analytics and equivalent services) that collect aggregated data about how users interact with our website and App, used to improve our Services. This data is anonymised or pseudonymised where possible.
(c) Marketing Pixels: Tracking pixels (including Meta Pixel, Google Ads conversion tracking, and similar tools) that enable us to measure the effectiveness of advertising campaigns and deliver targeted or remarketing advertisements to you on third-party platforms based on your prior interaction with our website.
(d) Email Tracking: Marketing emails may contain tracking pixels that record when an email is opened and whether links are clicked, used to measure email campaign performance.
7.3 Your Choices: You may manage cookie preferences through your browser settings or, where a cookie consent tool is provided on our website, through that tool. Disabling non-essential cookies will not prevent you from accessing the Services but may limit certain functionality. You may opt out of Google Analytics data collection by installing the Google Analytics Opt-Out Browser Add-On. You may opt out of personalised advertising through your social media platform settings.
7.4 EU/UK Consent Requirement: Where GDPR or UK GDPR applies, we will obtain your explicit consent before placing non-essential cookies on your device. Your continued use of our website without adjusting your cookie preferences where a consent mechanism is provided does not constitute consent under GDPR. We will respect your stated preferences.
7.5 Third-Party Tracking: Third-party platforms (including YouTube, Meta, and Google) may independently set cookies or tracking technologies when you interact with Smarternuthub content on their platforms. These are governed by those platforms' own privacy policies, over which Smarternuthub has no control.
SECTION 8: THIRD-PARTY SERVICES & DATA DISCLOSURE
8.1 When We Share Your Information
We do not sell, rent, or trade your Personal Information to any third party for their commercial purposes. We disclose Personal Information only in the following circumstances:
8.1.1 Service Providers: We share Personal Information with third-party service providers who process data on our behalf, including hosting and infrastructure providers (e.g., Systeme.io, GoDaddy), payment processors (e.g., Stripe), email service providers, and analytics providers. These providers are contractually bound to process data only on our instructions and to implement appropriate security measures.
8.1.2 Payment Processing: Payment information is processed directly by our nominated payment processor (e.g., Stripe). We receive confirmation of payment and transaction records but do not store full card details. Your payment data is governed by the payment processor's privacy policy.
8.1.3 Chargeback & Dispute Resolution: In the event of a payment dispute, chargeback, or fraud investigation, we will disclose relevant Personal Information — including account data, login records, IP address, device data, and content access logs — to our payment processor, issuing bank, or relevant financial authority, for the sole purpose of demonstrating the legitimacy of the charge. This disclosure is conducted on the basis of legitimate interests and legal obligation.
8.1.4 Legal Compliance & Law Enforcement: We may disclose Personal Information where required by law, court order, or lawful request from a regulatory or law enforcement authority in any jurisdiction. Where permitted by law, we will notify you of such a request before complying.
8.1.5 Business Transfer: In the event of a merger, acquisition, sale of assets, or other business transfer involving Smarternuthub, your Personal Information may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified of any such transfer.
8.1.6 With Your Consent: We may disclose your Personal Information for any other purpose with your express, specific consent.
8.2 Third-Party Platform Data
8.2.1 When you interact with Smarternuthub content on YouTube, Facebook, Instagram, LinkedIn, or any other third-party platform, the relevant platform collects data about your interaction in accordance with its own privacy policy. Smarternuthub is not responsible for the data practices of these platforms and has no ability to control what those platforms collect or how they use it.
8.2.2 Smarternuthub may receive aggregated or anonymised analytics data from these platforms about the performance of its content (e.g., video view counts, engagement metrics). Smarternuthub does not receive individually identifiable personal data from these platforms without your explicit consent to that disclosure.
8.2.3 Any Personal Information you voluntarily disclose in a public comment, post, or interaction on a third-party platform is public information. Smarternuthub has no duty of confidentiality in respect of information you choose to broadcast publicly. We recommend you do not share sensitive personal or health information in public forums.
8.3 No Sale of Personal Information
8.3.1 We do not sell, rent, lease, or otherwise exchange your Personal Information for monetary or other valuable consideration. This prohibition applies to Health Data, GLP-1 Data, and all other categories of Personal Information we collect.
8.3.2 For California residents: Consistent with the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), we do not sell or share your personal information for cross-context behavioural advertising without your opt-in consent.
SECTION 9: INTERNATIONAL DATA TRANSFERS
9.1 Smarternuthub is based in Queensland, Australia. Your Personal Information may be stored and processed in Australia, the United States, or other countries where our service providers operate. By using the Services, you acknowledge that your data may be transferred internationally.
9.2 Australian Users: Personal Information collected from Australian users is handled in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where data is transferred to overseas service providers, we take reasonable steps to ensure those providers handle data in a manner consistent with the APPs.
9.3 EU & UK Users: Where your Personal Information is transferred from the European Economic Area or United Kingdom to countries that have not been granted an adequacy decision, we implement appropriate safeguards as required by the GDPR and UK GDPR, including Standard Contractual Clauses (SCCs) or equivalent transfer mechanisms as approved by the relevant supervisory authority. You are entitled to request information about the transfer safeguards we use by contacting hello@smarternuthub.com.
9.4 All Other Jurisdictions: If you access the Services from a jurisdiction with data transfer restrictions, you do so voluntarily and acknowledge that your data may be transferred to and stored in jurisdictions with different privacy standards. Where mandatory laws in your jurisdiction impose specific transfer requirements that cannot be contractually displaced, Smarternuthub will comply with those requirements to the extent required by law.
Important: Unlike our previous policy, we do not seek to exclude or waive your rights under applicable data protection law. The protections afforded by the GDPR, UK GDPR, CCPA, and equivalent legislation cannot be contractually displaced and Smarternuthub does not attempt to do so. We comply with applicable law in each jurisdiction in which we operate.
SECTION 10: DATA RETENTION
We retain Personal Information only for as long as necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply:
10.1 Account & Membership Data: Retained for the duration of your active Membership or account, plus seven (7) years after account closure for financial, legal compliance, and dispute resolution purposes.
10.2 Health Data & GLP-1 Data: Retained for the duration of your active App Subscription. Upon cancellation, retained for a maximum of thirty (30) days, then permanently deleted. You may request earlier deletion under Section 11.
10.3 Payment & Transaction Records: Retained for seven (7) years from the date of transaction, as required for financial record-keeping and tax compliance.
10.4 Correspondence & Support Communications: Retained for three (3) years from the date of the most recent communication, or longer where required for legal proceedings or dispute resolution.
10.5 Chargeback & Dispute Evidence: Records relevant to chargeback disputes or legal proceedings are retained for the duration of those proceedings plus seven (7) years, or as required by applicable law.
10.6 Marketing Data: Email addresses collected for marketing purposes are retained until you withdraw consent or opt out, following which we will remove you from marketing communications within a reasonable timeframe. Your email address may be retained on a suppression list to ensure we do not inadvertently re-subscribe you.
10.7 Analytics & Technical Data: Aggregated and anonymised analytics data may be retained indefinitely. Identifiable technical data (including IP address logs) is retained for a maximum of twelve (12) months.
10.8 Community Content: Content you post in the Community is retained for the duration of your active Membership and for a period thereafter as required for legal and operational purposes. You may request deletion of Community posts under Section 11, subject to Smarternuthub's legitimate interest in maintaining records of Community interactions.
SECTION 11: YOUR PRIVACY RIGHTS
Depending on your jurisdiction, you may have the following rights in relation to your Personal Information. We will respond to all verifiable rights requests within the timeframe required by applicable law (generally thirty (30) days, with an extension available for complex requests):
11.1 Right of Access: You may request confirmation of whether we hold your Personal Information and, if so, a copy of that information, together with details of how it is used.
11.2 Right of Correction/Rectification: You may request that we correct inaccurate or incomplete Personal Information we hold about you.
11.3 Right of Erasure (Right to be Forgotten): You may request deletion of your Personal Information where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you object to processing and there is no overriding legitimate interest. Erasure requests in relation to Health Data and GLP-1 Data will be actioned promptly. Note that we may be required to retain certain information for legal, financial, or dispute resolution purposes even following an erasure request.
11.4 Right to Restrict Processing: You may request that we restrict processing of your Personal Information in certain circumstances, including while we verify the accuracy of disputed data.
11.5 Right to Data Portability: Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your Personal Information in a structured, commonly used, and machine-readable format.
11.6 Right to Object: You may object to processing based on legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
11.7 Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal. To withdraw consent, contact hello@smarternuthub.com.
11.8 Right Not to be Subject to Automated Decision-Making: We do not make decisions about you solely on the basis of automated processing that produce legal or similarly significant effects.
Australian Users: Your rights under the Privacy Act 1988 (Cth) include the right to access and correct your Personal Information and to complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au if you believe your privacy rights have been breached.
EU/UK Users: You have all rights set out in Articles 15–22 of the GDPR/UK GDPR. These rights are guaranteed by law and cannot be contractually limited. You also have the right to lodge a complaint with your local supervisory authority (e.g., your national Data Protection Authority in the EU, or the Information Commissioner's Office (ICO) in the UK). Contact details for EU supervisory authorities are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
California (US) Users: Under the CCPA/CPRA, you have the right to know what personal information we collect and how it is used, to delete personal information, to correct inaccurate information, to opt out of sale/sharing, to limit use of Sensitive Personal Information, and to non-discrimination for exercising your rights. To submit a CCPA rights request, contact hello@smarternuthub.com with "CCPA Rights Request" in the subject line.
To exercise any of the above rights, submit a written request to hello@smarternuthub.com with sufficient information to verify your identity. We may require additional verification before processing rights requests to protect against fraudulent requests.
SECTION 12: SECURITY
12.1 We implement reasonable technical and organisational security measures to protect your Personal Information against unauthorised access, alteration, disclosure, or destruction. These measures include encryption in transit (SSL/TLS), access controls, secure hosting infrastructure, and regular security reviews.
12.2 Health Data and GLP-1 Data are subject to enhanced security controls given their status as Sensitive Information. The optional App Security PIN provides an additional application-layer access control at your discretion.
12.3 No security measure is infallible. You acknowledge that no data transmission over the internet or method of electronic storage is one hundred percent (100%) secure, and that Smarternuthub cannot guarantee the absolute security of your Personal Information. You provide information to us at your own risk in this respect.
12.4 Data Breach Notification: In the event of a data breach that is likely to result in serious harm to affected individuals, Smarternuthub will notify affected individuals and the relevant regulatory authority (including the OAIC in Australia and applicable supervisory authorities in other jurisdictions) in accordance with applicable mandatory notification laws and within the timeframes required by those laws.
12.5 Limitation of Liability for Breaches: In the event of a data breach caused by circumstances outside Smarternuthub's reasonable control — including breaches of third-party service provider systems — Smarternuthub's liability is limited in accordance with the Terms of Service Limitation of Liability clause. However, nothing in this Policy limits liability for breaches of mandatory data protection law obligations that cannot be contractually excluded.
SECTION 13: EMAIL MARKETING & COMMERCIAL COMMUNICATIONS
13.1 Where you have opted in to receive marketing communications — including by downloading a free Digital Product, subscribing to a mailing list, or separately consenting during purchase — we may send you educational content, product updates, promotions, and other marketing communications by email.
13.2 All marketing emails will include a clear and functional unsubscribe mechanism. You may opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email or by contacting hello@smarternuthub.com. We will process opt-out requests within a reasonable timeframe, typically within ten (10) business days.
13.3 Opting out of marketing communications does not affect transactional communications, which we will continue to send as required to administer your account and subscription (e.g., payment confirmations, cancellation notices, price change notices).
13.4 We comply with the Australian Spam Act 2003 (Cth), the EU GDPR consent requirements for direct marketing, the UK Privacy and Electronic Communications Regulations (PECR), and the United States CAN-SPAM Act, as applicable to our subscribers in each jurisdiction.
13.5 Where you download a free Digital Product (GLP-1 Nutrition eBook or Supplement Guide), your email address may be used to send you follow-up educational content and marketing communications from Smarternuthub. This use will be clearly disclosed at the point of opt-in, and you may unsubscribe at any time.
SECTION 14: RECORDED CONTENT
14.1 All Membership Content, including Clinic Hours Content, is pre-recorded. It does not feature live interactions with members.
14.2 Where Smarternuthub conducts any live or interactive sessions in the future (including webinars, live Q&As, or group calls), participants will be notified at the commencement of the session that the session is being recorded. Continued participation after notice of recording constitutes consent to being recorded. Where a participant does not consent to recording, they may leave the session.
14.3 Recordings of any live sessions in which you participate — including your likeness, voice, and any information you voluntarily disclose — may be made available to other paying subscribers for educational purposes, in accordance with the licence granted in the Terms of Service.
14.4 To protect your privacy in any live interactive session, Smarternuthub may provide an anonymous question submission mechanism. If you disclose Sensitive Information during a live session by speaking or typing publicly rather than using the anonymous submission option, you do so voluntarily and accept that such disclosure may be captured in a recording accessible to other subscribers.
14.5 Once a recording has been published to the Membership library, Smarternuthub is not obligated to edit out or delete individual participant contributions, subject to any mandatory right of erasure you may hold under applicable law.
SECTION 15: CHILDREN'S PRIVACY
15.1 The Services are not directed at individuals under the age of 18 and we do not knowingly collect Personal Information from minors.
15.2 If you are under 18, you must not access or use the Services, submit any Personal Information to us, or download any Digital Product without the express involvement and approval of a parent or legal guardian.
15.3 If we become aware that we have collected Personal Information from an individual under 18 without verifiable parental consent, we will take steps to delete that information as promptly as reasonably practicable. If you believe a minor has submitted information to us, notify us at hello@smarternuthub.com.
SECTION 16: PRIVACY COMPLAINTS & DISPUTE RESOLUTION
16.1 Internal Complaints Process: If you have a complaint about how we have handled your Personal Information, please contact us in writing at hello@smarternuthub.com with the subject line "Privacy Complaint." We will acknowledge your complaint within five (5) business days and provide a substantive response within thirty (30) days. We will work with you in good faith to resolve the complaint.
16.2 External Complaints: If you are not satisfied with our response to your complaint, you may escalate your complaint to the relevant regulatory authority in your jurisdiction:
(a) Australia: Office of the Australian Information Commissioner (OAIC) — www.oaic.gov.au
(b) European Union: Your national Data Protection Authority — contact details at https://edpb.europa.eu
(c) United Kingdom: Information Commissioner's Office (ICO) — www.ico.org.uk
(d) United States: Federal Trade Commission (FTC) — www.ftc.gov; or your state's Attorney General for state-law complaints
(e) Other jurisdictions: The relevant national data protection or consumer protection authority
16.3 Dispute Resolution: Any legal dispute arising from this Privacy Policy is subject to the mandatory dispute resolution process, arbitration clause, and jurisdiction provisions set out in the Smarternuthub Terms of Service. However, nothing in this clause limits your right to lodge a complaint with a supervisory authority — that right exists independently of any dispute resolution clause and cannot be contractually displaced.
SECTION 17: GOVERNING LAW
17.1 This Privacy Policy is governed by and construed in accordance with the laws of Queensland, Australia, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
17.2 To the extent that mandatory data protection laws in other jurisdictions apply to our processing of your Personal Information — including the GDPR, UK GDPR, CCPA/CPRA, or any equivalent legislation — we comply with those laws as required. This Policy is intended to be read consistently with those mandatory obligations.
17.3 Nothing in this Policy displaces any right you hold under mandatory data protection legislation in your jurisdiction of residence.
SECTION 18: AMENDMENTS TO THIS POLICY
18.1 Smarternuthub reserves the right to update, amend, or replace this Privacy Policy at any time by publishing a revised version on the Smarternuthub website. The effective date at the top of the Policy will be updated accordingly.
18.2 Where amendments are material — including changes to how we use Health Data or GLP-1 Data, changes to third-party data sharing, or changes to your rights — we will notify you by email to your registered address at least fourteen (14) days before the changes take effect.
18.3 Your continued use of the Services following notification of material amendments constitutes your acceptance of the updated Policy. If you do not accept the amended Policy, you must cease use of the Services and contact us to close your account.
18.4 It is your responsibility to review this Policy periodically. The current version of this Policy is always available on the Smarternuthub website.
ACKNOWLEDGEMENT
By accessing, downloading, purchasing, or subscribing to any Smarternuthub product, service, or content — on any platform — you acknowledge that:
(a) you have read this Privacy Policy in its entirety;
(b) you understand how Smarternuthub collects, uses, stores, and discloses your Personal Information;
(c) you consent to the collection and processing of your Personal Information as described in this Policy;
(d) where you submit Health Data or GLP-1 Data to the App, you provide explicit consent to the collection of that Sensitive Information for the purposes described in Sections 4 and 6;
(e) you understand your rights under applicable privacy law and how to exercise them; and
(f) you are of legal age in your jurisdiction to consent to the collection and processing of your Personal Information.
Questions or concerns about this Privacy Policy should be directed to: hello@smarternuthub.com
Effective: November 30, 2025 | Smarternuthub | smarternuthub.com | hello@smarternuthub.com