Privacy Policy & Transparency Notice

Last updated: 14 July 2026
Applies to: Qina Hub website, personalised nutrition program, research participation, waitlist, community, rewards and partner services.

Qina Hub is designed to help people use their health, food and lifestyle data in a way that benefits them — not only the platforms, apps or companies collecting it.

We take your privacy seriously. This Privacy Policy explains what information we collect, how we use it, when we share it, how we protect it, and the choices you have.

Qina Hub is a Qina brand. For the purposes of this policy, “Qina Hub”, “Qina”, “we”, “us” and “our” refer to Qina LDA, PT515286834, Rua Jose Botelho 11, Olhao 8700-239, Portugal

For privacy questions or to exercise your rights, contact us at: [email protected]

1. Quick summary

When you use Qina Hub, we may collect information such as your name, email address, health goals, food habits, GLP-1 journey, symptoms, wearable data, questionnaire responses, coaching notes and product preferences.

We use this information to:

• provide personalised nutrition and health coaching;
• help you track progress and build long-term habits;
• recommend relevant food, nutrition, supplement, digital health and lifestyle products;
• invite you to suitable research or rewards opportunities, where you choose to take part;
• generate de-identified and aggregated insights for research, service improvement and partner innovation;
• improve the Qina Hub platform, content and member experience.

We do not sell your personal health data.
We do not share identifiable health data with ecosystem partners unless you have clearly agreed, or unless it is necessary to deliver a service you requested.
We do not use automated decision-making to make important decisions about your health, eligibility, insurance, employment or access to care.

 

 

2. Who this policy is for

This policy applies to:

• visitors to the Qina Hub website;
• people who join our waitlist;
• people who download our guides or resources;
• members of the Qina Hub personalised nutrition program;
• people taking part in research, surveys, pilots or rewards opportunities;
• people referred directly by pharmacies, employers, insurers, healthcare providers or other partners;
• coaches, clinicians, researchers, administrators and partner users who access Qina Hub services.

This policy does not replace any separate research consent form, participant information sheet, clinical consent, pharmacy policy or partner privacy notice that applies to a specific service, study or pilot. Where a specific research study has its own participant information sheet and consent form, those documents will explain the study-specific details.

 

 

3. What kind of service is Qina Hub?

Qina Hub provides a 12-month personalised nutrition and health support program for people who are using, considering, stopping or maintaining after GLP-1 medicines.

The program may include:

• personalised nutrition coaching;
• food, symptom and habit tracking;
• wearable and device data review;
• questionnaires and check-ins;
• product and service recommendations;
• educational content and community events;
• discounts, rewards or partner offers;
• optional research and data-sharing opportunities.

Qina Hub is not an emergency service. It does not replace medical advice from your doctor, pharmacist or healthcare professional.

 

 

4. Our role: controller, processor or partner

Depending on how you use Qina Hub, our data protection role may differ.

When you join Qina Hub directly

We are usually the data controller for the personal data you provide to us. This means we decide why and how your data is used to provide the program.

When you join through a pharmacy, employer, insurer, clinic or other partner

We may act as an independent controller, a joint controller, or a processor on behalf of that partner. The specific arrangement will depend on the partnership. We will tell you what applies at the point you join.

When you take part in a research study

The research sponsor, university, clinical organisation or commercial partner may be the controller for the study data. Qina Hub may act as a processor, joint controller or separate controller, depending on the study design. Your participant information sheet and consent form will explain this clearly.

 

 

5. What information we collect

We only aim to collect information that is relevant to providing, improving or evaluating the service.

A. Information you give us directly

As part of registration on the Qina hub website and for receiving reminder messages, this may include:

• name;
• email address;
• phone number;
• address
• location or country;
• login and account details;
• payment or subscription information if required;

 

B. Health, nutrition and lifestyle data

Because Qina Hub is a personalised nutrition and health service, some of the information we collect may be considered health data or special category data under data protection law depending on the project or research study. This data is securely collected and stored on the Third party platform.

This may include:

• age or date of birth;
• gender or sex, where relevant;
• communication preferences;
• health goals;
• diet preferences;
• food allergies or intolerances;
• cultural, religious or ethical food preferences;
• budget, cooking habits and lifestyle constraints;
• GLP-1 status, such as considering, starting, titrating, maintaining or stopping;
• medication information you choose to provide;
• symptoms and side effects;
• weight, height, BMI, waist circumference or body composition data;
• medical history or diagnoses you choose to share;
• questionnaire responses;
• free-text notes;
• coaching session notes;
• research consent choices;
• feedback, reviews or survey responses.
• Dietary intake;
• Shopping data
• protein and nutrient intake;
• hydration;
• appetite;
• cravings or “food noise”;
• nausea, constipation, reflux or other symptoms;
• energy and fatigue;
• mood and wellbeing;
• sleep;
• physical activity;
• muscle strength or function;
• body composition;
• metabolic health markers;
• blood test or biomarker data, where you choose to provide it;

C. Data from wearables, apps and devices

If you choose to connect a wearable, app or device, we may collect relevant data such as:

• steps;
• heart rate;
• sleep duration and sleep quality;
• activity and exercise;
• energy expenditure estimates;
• glucose data, where applicable;
• body weight or body composition from connected scales;
• other device-generated health or lifestyle metrics.

You can choose whether to connect these tools. You can disconnect them at any time, although this may reduce the level of personalisation we can provide.

D. Website and technical data

When you visit our website or platform, we may collect:

• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• referral source;
• approximate location based on technical data;
• date and time of visit;
• interactions with forms, emails or content;
• cookie and analytics data, where permitted.

We use this to keep the website secure, understand how people use our services, improve content and measure performance.

E. Data from partners

If you join Qina Hub through a pharmacy, clinic, insurer, employer, research organisation or other partner, they may share information with us so we can provide the service.

This may include:

• referral information;
• eligibility information;
• program status;
• medication or service information;
• contact details;
• partner access code;
• information needed to enrol you or support your journey.

The partner should explain what they share with us in their own privacy notice.

 

 

6. How we use your information

We use your information to provide, personalise, improve and evaluate Qina Hub services.

A. To provide the personalised nutrition program or research services

We use your data to:

• create and manage your account;
• understand your goals and starting point;
• personalise your nutrition and lifestyle plan;
• support coaching sessions;
• provide reminders and check-ins;
• track your progress over time;
• help identify patterns in symptoms, habits and outcomes;
• recommend relevant content, products or services;
• help you maintain progress during GLP-1 dose changes, stopping or long-term maintenance.

B. To provide expert-led and AI-supported insights

Qina Hub may use AI-supported tools to help organise, summarise or analyse information you provide.

For example, AI may help:

• summarise food logs;
• identify trends in wearable or questionnaire data;
• flag areas to discuss with your coach;
• personalise educational content;
• support product matching;
• improve the efficiency of coaching and program delivery.

AI is used as a support tool and is usually already integrated in the wearable data integrated with the platform where allowed. Important health-related guidance should be reviewed by a qualified professional. We do not use AI to make automated decisions that have legal or similarly significant effects on you.

C. To provide product recommendations, discounts, incentives and rewards

We may use your data to suggest relevant:

• foods;
• products;
• supplements;
• digital tools;
• wearable devices;
• home testing services;
• recipes;
• coaching resources;
• partner offers.

Where you choose to use a partner offer, we may share limited information needed to activate that offer, such as your name, email address, discount code or eligibility status.

D. To support research and innovation

With your explicit consent or where permitted by law, we may use data to support research and innovation in personalised nutrition, GLP-1 support, metabolic health, behaviour change, food products and healthspan.

This may include:

• surveys;
• questionnaires;
• observational studies;
• product feedback;
• real-world evidence projects;
• service evaluations;
• data insights for food, health, wellness, pharmacy or research partners.

In all cases, we use de-identified, pseudonymised or aggregated data only.

E. To provide partner insights

One of Qina Hub’s goals is to create a fairer model where members can benefit from their data and partners can improve products and services based on real-world outcomes. We will seek explicit consent on each occasion.

We may provide pharmacies, healthcare organisations, food companies, ingredient companies, wellness brands, insurers or research partners with reports such as:

• engagement trends;
• adherence patterns;
• symptom trends;
• product preference insights;
• behaviour change patterns;
• unmet needs;
• anonymised feedback;
• aggregated outcome measures.

These reports are designed to help partners improve services and products whilst we reinvest the fee charged for these reports to give back to the users. They should not identify you as an individual unless you have specifically agreed.

F. To communicate with you

We may contact you about:

• your account;
• program updates;
• coaching sessions;
• reminders;
• surveys or check-ins;
• research opportunities;
• rewards or partner offers;
• privacy or security notices;
• newsletters or marketing, where you have opted in or where the law allows.

You can unsubscribe from marketing communications at any time.

G. To improve and protect our services

We use data to:

• test and improve our platform;
• understand user needs;
• improve website content and conversion;
• monitor service quality;
• prevent fraud, misuse or security incidents;
• comply with legal, regulatory, tax and accounting obligations;
• resolve disputes or enforce our terms.

 

7. Our legal bases for using your data

We rely on different legal bases depending on the context.

These may include:

Consent

We may rely on your consent for:

• processing health data;
• connecting wearable or device data;
• sending marketing emails;
• inviting you into research;
• using identifiable data for a specific study;
• sharing data with selected partners where consent is required.

You can withdraw consent at any time.

Contract

We may process your data to provide the services you signed up for, such as the personalised nutrition program or research.

Legitimate interests

We may process some data for legitimate business purposes, such as improving our website, analysing service performance, preventing fraud and creating aggregated insights, provided your rights and freedoms are protected.

Legal obligation

We may process data where required by law, such as tax, accounting, safeguarding, regulatory or legal obligations.

Research and public interest

In some cases, research processing may rely on additional legal bases or safeguards. These will be explained in the relevant participant information sheet or study documents.

 

 

8. Special category health data

Health data is sensitive. We will only process this type of data where we have an appropriate legal basis and additional safeguards.

This may include:

• your explicit consent;
• the provision of health or nutrition-related services;
• research safeguards;
• legal or regulatory obligations;
• protection of vital interests in rare or emergency situations.

We aim to collect the minimum health data needed for the purpose explained to you.

 

 

9. Research participation

You may be invited to take part in research, surveys, pilots or rewards opportunities. Participation is entirely optional.

Before you take part, we will explain:

• who is running the research;
• what the purpose is;
• what data will be collected;
• whether the data is identifiable, pseudonymised, de-identified or anonymised;
• who will see the data;
• whether partners are involved;
• whether there are incentives, discounts or rewards;
• how long the data will be kept;
• whether results may be published;
• how to withdraw, where withdrawal is possible.

You can use Qina Hub without taking part in optional research, unless a specific pilot or study is clearly described as research-only.

 

 

10. De-identified, aggregated and anonymised data

We may use data that has been de-identified, aggregated or anonymised to:

• improve the Qina Hub service;
• understand what works for different groups of people;
• support research and real-world evidence;
• develop new nutrition, food, supplement or health solutions;
• create reports for partners;
• publish insights;
• inform product and service innovation.

Where data is truly anonymised, it no longer identifies you and data protection law may not apply to it.

 

11. Who we share data with

We only share personal data where there is a clear reason and appropriate safeguards.

A. Qina Hub team and coaches

Relevant team members, coaches, nutrition professionals, researchers, technical staff and administrators may access your data where needed to provide the service.

B. Healthcare professionals or clinicians

If you choose to share your information with your doctor, we support this request, but it is not standard practice.

If you join through a partner pharmacy or clinic, they will only receive aggregated data.

C. Research organisations

If you consent to take part in a research study, relevant research staff may access the data described in the participant information sheet and consent form.

D. Pharmacies and ecosystem partners

We may share de-identified or aggregated insights with partners to help them improve products, services and customer support.

E. Service providers

We may use trusted service providers to help us run Qina Hub, such as:

• website hosting providers;
• cloud storage providers eg AWS;
• email and SMS providers eg Google or Microsoft;
• payment processors eg Stripe;
• analytics tools;
• survey tools;
• customer support tools;
• video call platforms eg Zoom;
• wearable/device integration services eg Dexcom;
• AI and data-processing providers;
• security and compliance providers eg Cloudflare.

These providers are only allowed to process data according to our instructions and must protect it appropriately.

F. Legal or safety reasons

We may share information if required to:

• comply with the law;
• respond to a court order or regulator;
• prevent fraud or security threats;
• protect someone’s vital interests;
• safeguard children or vulnerable adults;
• enforce our terms;
• manage a business sale, merger or restructuring.

 

12. International data transfers

We aim to store and process personal data in the UK, European Economic Area, or other locations with appropriate safeguards.

Where personal data is transferred outside the UK or EEA, we will use recognised safeguards such as adequacy decisions, standard contractual clauses or equivalent protections.

 

 

13. How long we keep your data

We keep data only for as long as needed for the purpose it was collected, unless we are required to keep it longer by law.

Typical retention periods may include:

• waitlist and marketing data: until you unsubscribe or ask us to delete it;
• account data: while your account is active;
• program data: for the duration of your program and a reasonable period afterwards;
• coaching notes: for as long as needed to provide continuity of support and meet legal or professional obligations (eg 10 years);
• research data: for the period stated in the study documents;
• financial records: as required by tax and accounting law;
• anonymised data: may be kept indefinitely because it no longer identifies you.

If you close your account, we will delete or anonymise personal data where possible, unless we need to keep it for legal, regulatory, research integrity, safety or dispute-resolution reasons.

 

 

14. How we protect your data

We use technical and organisational measures to protect your information.

These may include:

• encryption in transit;
• encryption at rest where appropriate;
• access controls;
• role-based permissions;
• staff training;
• confidentiality obligations;
• audit logs;
• secure hosting;
• supplier due diligence;
• data minimisation;
• incident response processes;
• regular review of policies and procedures.

No digital service can guarantee absolute security, but we work to protect your data using appropriate safeguards.

 

 

15. Cookies and analytics

We may use cookies, pixels, local storage or similar technologies to:

• keep the website working;
• remember your preferences;
• understand website traffic;
• improve content and user experience;
• measure marketing performance;
• support security and fraud prevention.

Where required, we will ask for your consent before using non-essential cookies.

You can manage cookies through your browser settings or cookie banner, where available.

 

 

16. Marketing communications

If you sign up for our waitlist, guides, newsletter or program updates, we may send you relevant emails about the Qina Hub, research opportunities or program launches.

You can unsubscribe at any time using the link in our emails or by contacting us.

We will not sell your contact details to third parties.

 

 

17. Your choices and rights

Depending on where you live and the law that applies, you may have rights to:

• access your personal data;
• correct inaccurate data;
• delete your data;
• restrict how your data is used;
• object to certain processing;
• withdraw consent;
• receive a copy of your data in a portable format;
• complain to a data protection authority;
• ask questions about automated processing.

To exercise your rights, contact us at [email protected].

We may need to verify your identity before responding. We aim to respond within the timeframe required by applicable law.

 

 

18. Withdrawing consent

Where we rely on consent, you can withdraw it at any time.

Withdrawing consent will not affect processing that happened before withdrawal. It may also mean that we can no longer provide some personalised features, research participation, rewards or connected-device services.

For research studies, the participant information sheet will explain what happens if you withdraw and whether data already collected can still be used.

 

 

19. Automated decision-making and profiling

We do not use automated decision-making to make legally or similarly significant decisions about you.

Where AI or algorithmic tools are used, they are intended to support human-led coaching, research and service improvement.

 

 

20. Children

Qina Hub is intended for adults aged 18 and over.

We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, contact us so we can take appropriate action.

 

 

21. Complaints

If you are unhappy with how we handle your data, please contact us first at [email protected] so we can try to resolve the issue.

You may also have the right to complain to your local data protection authority.

For example:

• in the UK, this may be the Information Commissioner’s Office;
• in Portugal, this may be the Comissão Nacional de Proteção de Dados;
• in another EU country, this may be your national data protection authority.

 

22. Links to other websites and partner services

Qina Hub may link to partner websites, online pharmacies, product stores, apps, wearable platforms, testing services or research portals.

We are not responsible for the privacy practices of third-party websites or services. Please read their privacy notices before sharing information with them.

 

 

23. Changes to this policy

We may update this Privacy Policy from time to time.

If we make important changes, we will take reasonable steps to tell you, such as posting an update on the website or contacting you by email.

The latest version will always be available on this page.

 

 

24. Contact us

For questions, privacy requests or complaints, contact:

Qina Hub / Qina LDA
Email: [email protected]
Address: Rua Jose Botelho 11, Olhao 8700-239
Data protection contact: Adriana Sales, [email protected]

Your health data should work for you. Qina Hub uses your information to personalise your support, help you track progress, and improve food and health solutions for people like you. We will be transparent about what we collect, why we collect it, and when you have a choice.