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Legal / Data Subject & Consumer Request Procedure

Data Subject & Consumer Request Procedure

Version 5.0.0 · Effective 2026-10-18 · Operator Nativity Ltd

At a glance

  • Email [email protected] to exercise your privacy rights.
  • In the product, you can correct many fields yourself.
  • To close an account, use account settings or email us.
  • A self-serve export may not include everything (for example, AI conversation bodies). Email [email protected] for a fuller copy.
  • We delete identifiable account and planner data from our active systems when you close your account, with the limits described below.
  • We aim to respond within approximately 1 month under GDPR and approximately 45 days under CCPA, with extensions where the law allows.
  • The Services are for adults aged 18+.

The full terms below control.

Contents

  1. 1. Who Can Request
  2. 2. Rights We Honor
  3. 3. How To Request
  4. Email (primary)
  5. In-Product Correction
  6. Close An Account
  7. Product Support
  8. 4. Identity Verification
  9. 5. Export & Portability
  10. 6. Deletion
  11. 7. Timelines
  12. 8. Fees
  13. 9. Refusal, Partial Response, Appeals
  14. 10. Children
  15. Contact

1. Who Can Request

Requester Scope
Account holder Personal Data we process about your Optimal account and Environments
Authorized agent Where permitted by law (for example, CCPA/CPRA), with proof of authorization
Parent or guardian Where applicable for a minor we should not have onboarded. See the age section in the Privacy Policy

Nativity Ltd is the Controller for account, health profile, meal, journal, AI conversation, and related product data. Infrastructure vendors are processors or sub-processors. Named vendors appear in the Sub-processor List.


2. Rights We Honor

We honor rights available under applicable data-protection laws. Exact scope depends on your location and the law that applies.

Right Typical regimes How we handle
Access / know GDPR, UK GDPR, CCPA/CPRA, and similar laws We provide categories and, where required, a copy of Personal Data we hold
Rectification / correction Most laws We correct inaccurate account or profile data. Many fields are editable in-product
Erasure / deletion GDPR Article 17, CCPA delete, and similar We close the account and delete identifiable data from active systems, subject to Section 6
Restriction GDPR / UK GDPR We limit processing where legally required
Objection GDPR / UK GDPR You may object to processing based on legitimate interests or direct marketing
Portability GDPR / UK GDPR Structured export. Self-serve export may be partial. Contact us for more
Opt out of sale or share CCPA/CPRA We do not sell Personal Data for money. See the Privacy Policy for our analysis of limited outbound partner click metrics
Limit use of sensitive personal information CCPA/CPRA Health and pregnancy data are core to the product. Contact [email protected]
Human review of automated processing GDPR Article 22 posture Scores and AI outputs are informational, not medical decisions. See Automated Decisions and AI Transparency
Withdraw consent GDPR Articles 7 and 9 Change your choices in the Privacy Center (the separate consents for health-detail, weight and ancestry analytics signals, the two sponsor-matching switches, sponsor notifications, and the analytics opt-out), stop using AI, disable push, or close your account. Withdrawal stops further collection. It does not undo processing that was already lawful or remove figures already published in aggregate

If a right is not available in your jurisdiction, we may still honor reasonable requests as a matter of practice.


3. How To Request

Email (primary)

Email [email protected] and include:

  1. The type of request (access, correction, erasure, portability, restriction, objection, CCPA know/delete/opt-out, or another right).
  2. The email address associated with your account, and any prior emails if you changed it.
  3. Enough detail to locate records, including the Environment name if relevant.
  4. For agents, we require proof of authorization and identity of the consumer.

In-Product Correction

You can correct many profile, preference, meal, and journal fields directly in the signed-in Services without a formal request.

Close An Account

To close an account, use account settings or email [email protected]. We will help if you cannot complete closure yourself.

Product Support

Product questions that are not legal rights requests should be sent to [email protected]. We may route privacy matters to [email protected].


4. Identity Verification

To protect Special Category Health Data and other Personal Data, we verify the requester before disclosing or acting.

Check Practice
Account match The request email and account identifiers must match our records
Signed-in actions Where appropriate, we prefer actions from a signed-in account
Heightened scrutiny For erasure or bulk access, we may ask for additional confirmation
Agents Valid authorization plus consumer identity verification as required by law
Failure to verify We will not disclose or delete until identity is reasonably verified

We do not request government identification where less intrusive verification works.


5. Export & Portability

A self-serve export may not include everything. For example, it may omit AI conversation bodies.

For a fuller copy of what we hold, please contact [email protected]. We will provide what we can reasonably assemble from systems we control, subject to verification and the limits outlined in other Sections.


6. Deletion

When you close your account:

  • We delete your account and the records held under it. A few pseudonymised records are kept, including proof of what you agreed to and certain payment records (Privacy Policy, Section 13).
  • When you delete your account, the forum profile is anonymized (Privacy Policy, Section 13). Your posts and uploads are not deleted and remain visible under an anonymous identifier.
  • Backups, security logs, email logs, and our processors may keep copies for a limited time under their own rules.
  • We do not currently instruct AI Model Providers to delete their copies. Those copies follow their terms.
  • Anonymous participations prevent identification and cannot be taken back. Anonymized or aggregated statistics that no longer identify you are retained and cannot be withdrawn, because no individual record remains to remove.
  • Legal holds and mandatory retention (including Legal hold suspends deletion where required by law) can delay erasure.

We do not issue a formal deletion certificate. If something still looks linked to you after closure, contact [email protected].


7. Timelines

Framework Target response time
GDPR / UK GDPR Approximately 1 month from receipt, extendable for complex or numerous requests. We will tell you if we extend.
CCPA/CPRA Approximately 45 days, extendable by 45 days with notice.
Other regions Without undue delay, and within local statutory limits.

We aim to acknowledge requests promptly.


8. Fees

Requests are free of charge, except where a law permits a reasonable fee for manifestly unfounded, excessive, or repetitive requests. We will explain any fee before charging.


9. Refusal, Partial Response, Appeals

We may refuse or limit a request where:

  • Identity cannot be verified.
  • A legal hold or mandatory retention applies.
  • Disclosure would adversely affect others' rights and freedoms.
  • The request is manifestly unfounded or excessive.
  • An exemption under the relevant law applies.

We will explain the basis for a refusal or partial response. You may:

  1. Reply to [email protected] to appeal or provide more information.
  2. Lodge a complaint with a supervisory authority (see the Privacy Policy).
  3. Seek judicial remedy where available.

10. Children

The Services are directed at adults with a self-attested age 18+. We do not knowingly process children's data as users. If you believe we hold a child's data, please contact [email protected] for prompt deletion.


Contact

Topic Contact
Privacy rights [email protected]
Product support [email protected]

See also the Privacy Policy, Automated Decisions and AI Transparency, and Sub-processor List.

Content hash: 659d17e50d57… · Built 2026-10-18

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Optimal Being is operated by Nativity Ltd, trading as Optimal. Registered in England and Wales, company no. 17457413. Registered office: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF.