Privacy Policy

Effective Date: 1st August, 2025

At PRECISION NUTRITION ADVISORY LTD (“we” or “us” or “our”), we are committed to protecting the

privacy and personal information of our users (“user” or “you”). This Privacy Policy explains how we collect,

use, process, disclose, and safeguard your information when you visit our website or interact with our digital

services.

By using our services, you consent to the practices described in this Privacy Policy.

WHO WE ARE

We are Precision Nutrition Advisory Ltd, a growing nutrition and public health company committed to

transforming nutrition through evidence.

For any privacy concerns, contact us at;

Email: work@pnaglobal.org

Number: +234 8162854316, +1 (437) 535-3251

1. WHAT PERSONAL DATA WE COLLECT

We collect personal information that you voluntarily provide to us when you express an interest in obtaining

information about us or our products and services, when you participate in activities on the services, or

otherwise when you contact us.

1. a) Personal Identification Information

The personal information that we collect depends on the context of your interactions with us and the services,

the choices you make, and the features you use. The personal information we collect may include the

following;

• Full name
• Email address
• Phone number
• Location Information (optional or inferred)

1. b) Health and Wellness Information (Sensitive Personal Data)

When necessary, with your consent or as otherwise permitted by applicable law, we process the following

categories of sensitive information;

• Dietary preferences or restrictions
• Allergies
• Health or fitness goals
• Information from wellness assessments or consultations

This information is collected only with your explicit consent and used solely for wellness service delivery.

1. c) Usage and Technical Data

• IP address
• Device and browser type
• Pages visited, clicks, and interaction time
• Cookies and similar technologies (see below)This information is primarily needed to maintain the security and operation of our website, for troubleshooting,

and for our internal analytics and reporting purposes.

All personal and sensitive information that you provide to us must be true, complete, and accurate, and you

must notify us of any changes to such personal information.

1. d) Information Automatically Collected

Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is

collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the services. This information

does not reveal your specific identity (like your name or contact information) but may include device and

usage information, such as your IP address, browser and device characteristics, operating system, language

preferences, referring URLs, device name, country, location, information about how and when you use our

Services, and other technical information. This information is primarily needed to maintain the security and

operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find

out more about this in our Cookie Notice (see below).

The information we collect includes:

• Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance

information our servers automatically collect when you access or use our Services and which we

record in log files. Depending on how you interact with us, this log data may include your IP address,

device information, browser type, and settings and information about your activity in the Services

(such as the date/time stamps associated with your usage, pages and files viewed, searches, and

other actions you take such as which features you use), device event information (such as system

activity, error reports (sometimes called “crash dumps”), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other

device you use to access the Services. Depending on the device used, this device data may include

information such as your IP address (or proxy server), device and application identification numbers,

location, browser type, hardware model, Internet service provider and/or mobile carrier, operating

system, and system configuration information.

• Location Data. We collect location data such as information about your device’s location, which can

be either precise or imprecise. How much information we collect depends on the type and settings of

the device you use to access the Services. For example, we may use GPS and other technologies to

collect geolocation data that tells us your current location (based on your IP address). You can opt

out of allowing us to collect this information either by refusing access to the information or by disabling

your Location setting on your device. However, if you choose to opt out, you may not be able to use

certain aspects of the Services.

1. e) Information Collected from Other Sources

We may collect limited data from public databases, marketing partners, social media platforms, and other

outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our

records, we may obtain information about you from other sources, such as public databases, joint marketing

partners, affiliate programs, data providers, social media platforms, and from other third parties. This

information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom

profiles, for purposes of targeted advertising and event promotion.

If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter),

we receive personal information about you such as your name, email address, and gender. Any personal

information that we collect from your social media account depends on your social media account’s privacy

settings.

1. WHY WE COLLECT AND HOW WE USE YOUR INFORMATION

We collect and process your information to provide, improve, and administer our Services, communicate with

you, for security and fraud prevention, and to comply with law. We may also process your information for

other purposes with your consent.

We collect and process your personal information for a variety of reasons, depending on how you interact

with our Services, including:

• To facilitate account creation, authentication and otherwise manage user accounts. We may process

your information so you can create and log in to your account, as well as keep your account in working

order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide

you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to

your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about

our products and services, changes to our terms and policies, and other similar information.

• To fulfill and manage your orders. We may process your information to fulfill and manage your orders,

payments, returns, and exchanges made through the Services.

• To enable user-to-user communications. We may process your information if you choose to use any

of our offerings that allow for communication with another user.

• To request feedback. We may process your information when necessary to request feedback and to

contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information

you send to us for our marketing purposes, if this is in accordance with your marketing preferences.

You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR

PRIVACY RIGHTS?” below).

• To deliver targeted advertising to you. We may process your information to develop and display

personalized content and advertising tailored to your interests, location, and more. For more

information see our Cookie Notice below.

• To protect our Services. We may process your information as part of our efforts to keep our Services

safe and secure, including fraud monitoring and prevention.

• To identify usage trends. We may process information about how you use our Services to better

understand how they are being used so we can improve them.• To determine the effectiveness of our marketing and promotional campaigns. We may process your

information to better understand how to provide marketing and promotional campaigns that are most

relevant to you.

• To save or protect an individual’s vital interest. We may process your information when necessary to

save or protect an individual’s vital interest, such as to prevent harm.

1. LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION

We only process your personal information when we believe it is necessary and we have a valid legal reason

(i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you

with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate

business interests.

If you are located in Nigeria, this section applies to you:

Under the Nigerian Data Protection Act, we can only use your personal information if we have a proper reason

for doing so. In order to use your personal information, we rely on the following legal bases:

• Performance of the service contract between you and us. Processing is necessary for us to be able

to provide our products and services to you in accordance with our Terms and Conditions;

• processing is necessary to comply with our legal obligations;
• processing is necessary for the purposes of legitimate business interests pursued by us, where these

do not override your rights and freedoms; and

• you have provided consent to the processing of your personal data for a specific purpose.

If you are located in the EU or UK, this section applies to you:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases

we rely on in order to process your personal information. As such, we may rely on the following legal bases

to process your personal information:

• We may process your information if you have given us permission (i.e., consent) to use

your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a Contract. We may process your personal information when we believe it is

necessary to fulfill our contractual obligations to you, including providing our Services or at your

request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary

to achieve our legitimate business interests and those interests do not outweigh your interests and

fundamental rights and freedoms. For example, we may process your personal information for some

of the purposes described in order to:

o Send users information about special offers and discounts on our products and services

o Develop and display personalized and relevant advertising content for our users

o Analyse how our services are used so we can improve them to engage and retain users

o Support our marketing activities

o Diagnose problems and/or prevent fraudulent activitieso Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for

compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory

agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in

which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your

vital interests or the vital interests of a third party, such as situations involving potential threats to the

safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal

information described in this privacy notice, since we determine the means and/or purposes of the data

processing we perform. This privacy notice does not apply to the personal information we process as a “data

processor” on behalf of our customers. In those situations, the customer that we provide services to and with

whom we have entered into a data processing agreement is the “data controller” responsible for your personal

information, and we merely process your information on their behalf in accordance with your instructions. If

you want to know more about our customers’ privacy practices, you should read their privacy policies and

direct any questions you have to them.

If you are located in Canada, this section applies to you:

We may process your information if you have given us specific permission (i.e., express consent) to use your

personal information for a specific purpose, or in situations where your permission can be inferred (i.e.,

implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information

without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle

an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial

abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the

accuracy of the information and the collection is reasonable for purposes related to investigating a

breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating

to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the

collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations4. WHO MAY ACCESS YOUR INFORMATION

We may share information in specific situations described in this section and/or with a specified category of

third parties.

Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party

vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our

behalf and require access to such information to do that work. We have contracts in place with our third

parties, which are designed to help safeguard your personal information. This means that they cannot do

anything with your personal information unless we have instructed them to do it. They will also not share your

personal information with any organization apart from us. They also commit to protect the data they hold on

our behalf and to retain it for the period we instruct. The categories of third parties we may share personal

information with are as follows:

• Ad Networks
• Affiliate Marketing Programs
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Government Entities
• Order Fulfilment Service Providers
• Payment Processors
• Performance Monitoring Tools
• Product Engineering & Design Tools
• Retargeting Platforms
• Sales & Marketing Tools
• Social Networks
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during

negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our

business to another company.• Affiliates: We may share your information with our affiliates, in which case we will require those

affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint

venture partners, or other companies that we control or that are under common control with us.

• Business Partners: We may share your information with our business partners to offer you certain

products, services, or promotions.

• Other Users: When you share personal information (for example, by posting comments,

contributions, or other content to the Services) or otherwise interact with public areas of the Services,

such personal information may be viewed by all users and may be publicly made available outside

the Services in perpetuity. If you interact with other users of our Services and register for our Services

through a social network (such as Facebook), your contacts on the social network will see your name,

profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions

of your activity, communicate with you within our Services, and view your profile.

• By Law or To Protect Rights: If we believe the release of information about you is necessary to

respond to legal process, comply with regulatory authorities, to investigate or remedy potential

violations of our policies, or to protect the rights, property, and safety of others, we may share your

information as permitted or required by any applicable law, rule, or regulation.

• Third-Party Service Providers: We are not responsible for the safety of any information that you

share with third parties that we may link to or who advertise on our Services, but are not affiliated

with, our Services. The Services may link to third-party websites, online services, or mobile

applications and/or contain advertisements from third parties that are not affiliated with us and which

may link to other websites, services, or applications. Accordingly, we do not make any guarantee

regarding any such third parties, and we will not be liable for any loss or damage caused by the use

of such third-party websites, services, or applications. The inclusion of a link towards a third-party

website, service, or application does not imply an endorsement by us. We cannot guarantee the safety

and privacy of data you provide to any third parties. Any data collected by third parties is not covered

by this privacy notice. We are not responsible for the content or privacy and security practices and

policies of any third parties, including other websites, services, or applications that may be linked to

or from the Services. You should review the policies of such third parties and contact them directly to

respond to your questions.

In all cases, we limit sharing to what is necessary and ensure appropriate safeguards are in place. At no time

will our database of users ever be sold to any entity for the purpose of marketing or mailing lists.

1. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on our website to enhance user experience, understand

usage patterns, and deliver tailored content.

Cookies may be used to:

• Remember your preferences and settings (e.g., location, language, login status)
• Analyse website performance and visitor behaviour through tools like Google Analytics
• Support marketing campaigns and retargeting ads, including showing relevant promotions on other

platforms

• Improve site functionality, such as page load speed or remembering form inputs

Cookies may be first-party (set by us) or third-party (set by service providers like analytics or ad platforms).You can choose to accept or reject cookies through:

• Your browser settings (to block or delete cookies)
• Our website’s cookie banner or pop-up on your first visit

By continuing to use our site without adjusting your settings, you consent to our use of cookies as described

above.

For more information on how we use your data, please review our Cookie Policy.

1. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security

measures.

We have implemented appropriate and reasonable technical and organizational security measures designed

to protect the security of any personal information we process. However, despite our safeguards and efforts

to secure your information, no electronic transmission over the Internet or information storage technology

can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or

other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal,

or modify your information. Although we will do our best to protect your personal information, transmission of

personal information to and from our Services is at your own risk. You should only access the Services within

a secure environment.

1. DATA RETENTION AND SECURITY

We retain your personal data only for as long as it is necessary to fulfill the purposes for which it was collected.

These purposes may include providing our services to you, maintaining business records, complying with

legal obligations, resolving disputes, and enforcing our agreements.

The duration for which we keep your data depends on the type of information and the context in which it was

collected. For example:

• Contact information such as your name and email address are retained until you unsubscribe or

request deletion.

• Health-related information, such as wellness goals or dietary inputs, is kept for a limited period,

typically 12 to 24 months, unless we are required by law to retain it for longer.

• Website usage data collected via cookies or analytics tools may be retained for between 6 to 18

months.

• Records of transactions or services provided may be stored for up to 5 years to comply with

accounting or legal requirements.

When data is no longer required, we will securely delete it, anonymize it, or store it in a secure, archived

environment with restricted access. You have the right to request that we delete your personal data at any

time, subject to any legal or regulatory retention obligations. Requests can be sent to _____________

Data Security: We take the protection of your personal data seriously and have put in place appropriate

technical, administrative, and organizational safeguards to secure it from unauthorized access, loss, misuse,

or alteration.

These security measures include:• The use of SSL encryption to protect data transmitted on our website.

• Access controls to ensure that only authorized personnel can access sensitive data.
• Secure storage systems with firewall and anti-malware protections.
• Password protection and authentication procedures for internal systems.
• Staff confidentiality agreements and regular privacy training for our team.
• Data minimization practices to ensure we only collect what is necessary.

While we strive to use industry-standard means to protect your data, no method of transmission over the

Internet or method of electronic storage is 100% secure. In the unlikely event of a data breach that affects

your personal information, we will promptly notify you and the appropriate regulatory authorities, as required

by applicable law.

1. YOUR RIGHTS AND CHOICES AS A DATA SUBJECT

The Nigerian Data Protection Act (NDPA) grants you significant control over your personal information. You

have the right to:

• Be informed and provided with clear, transparent and easily understandable information about how

we use your information and your rights. This is why we’re providing you with the information in

this Privacy Policy

• Access your personal information
• Request correction of inaccurate data
• Request deletion of your data (subject to legal requirements)
• Object to certain processing of your data
• Request restriction of processing (how we use your information)
• Data portability (transfer your data to other service provider)
• Withdraw consent at any time, though this may affect our ability to provide certain services

To exercise any of these rights, simply contact our Data Protection Officer using the details provided at the

end of this Policy. We’re committed to addressing your concerns promptly and transparently.

INTERNATIONAL ASPECTS OF DATA PROTECTION

In today’s interconnected world, data sometimes needs to flow across borders. If we transfer your information

outside Nigeria, we implement appropriate safeguards in compliance with the NDPA. These include;

• Data transfer agreements with standard contractual clauses
• Ensuring recipient countries have adequate data protection regulations
• Obtaining your explicit consent where required

1. POLICY FOR CHILDREN

We do not knowingly collect data from or market to children under 18 years of age.We do not knowingly solicit data from or market to children under 18 years of age. By using the Services,

you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to

such minor dependent’s use of the Services. If we learn that personal information from users less than 18

years of age has been collected, we will deactivate the account and take reasonable measures to promptly

delete such data from our records.

If you become aware of any data, we may have collected from children under age 18, please contact us at

work@pnaglobal.org or +234 8162854316, +1 (437) 535-3251 .

1. HEALTH DISCLAIMER

The information provided on our website, mobile platform, blog, emails, social media channels, and other

digital communications is intended for educational and informational purposes only. While our content

may be based on credible research, expert insight, or general wellness principles, it is not a substitute for

professional medical advice, diagnosis, or treatment.

You should always:

• Seek the advice of a qualified medical or healthcare professional before starting any diet, nutrition,

fitness, or wellness program based on information obtained from our platform.

• Never disregard professional medical advice or delay seeking it because of something you read or

accessed through our services.

• Understand that individual health needs vary, and what works for one person may not be suitable for

another.

Use of our platform does not establish a doctor-patient or clinical relationship, and we do not offer

clinical or emergency medical care. If you are experiencing a medical emergency, please call your doctor

or local emergency services immediately.

Precision Nutrition Advisory Ltd shall not be held liable for any direct, indirect, incidental, or consequential

damages resulting from the use or misuse of information obtained through our services.

1. CHANGES TO THIS PRIVACY POLICY

We may update or modify this Privacy Policy periodically to reflect changes in our practices, technology, legal

requirements, or for other operational reasons. All updates will be effective upon posting the revised version

on our website, with the “Last Updated” date clearly indicated at the top or bottom of this page.

Where changes are material, such as introducing new purposes for processing your data or significantly

changing how we handle sensitive personal information, we will:

• Provide prominent notice on our homepage or platform
• Notify you directly via email or other contact channels where applicable

We encourage you to review this Privacy Policy from time to time to stay informed about how we are

protecting your data and upholding your privacy rights.

Last updated: 1st August 2025

CONTACT US

If you have any questions, concerns, complaints, or would like to exercise your rights under this Privacy

Policy, please contact us through any of the following means:

PRECISION NUTRITION ADVISORY LTD

Email: work@pnaglobal.org

Phone: +1 (437) 535-3251, +234 8162854316

Address: Lifecamp, Abuja FCT Nigeria

We take all privacy-related communications seriously and aim to respond to your inquiry or request within 7

working days.