Last Updated: November 7th 2023.
1. Who We Are
Under this Policy, the terms below have the meanings ascribed to them:
- CCPA/CPRA refers to the California Consumer Privacy Act / California Privacy Rights Act that applies to users who reside and use our Services from the State of California, US.
- GDPR refers to the General Data Protection Regulation, a privacy law that concerns users in the European Union (EU), European Economic Area (EEA), United Kingdom (UK), and countries under the same law.
- PIPEDA refers to Personal Information Protection and Electronic Documents Act, a privacy law that concerns users in Canada.
- we, us, and our all refer to the Company and any affiliated entities.
- you and your refer to anyone accessing the Website and using our Services, including professionals, visitors, and individual users.
2. Your Consent
You acknowledge and consent to our collection, use, and disclosure of your personal information as it is critical for your use and access to the Website and Services. We rely on the following actions by you as indications of your consent to our existing and future privacy practices:
- Your voluntary provision of information directly to us to use our Services, or to participate in or attend an event or promotion we offer (including information previously provided to us);
- Your express consent or acknowledgment contained within a written, verbal, or electronic application process;
- Your consent solicited by the Company for a specified purpose;
- Your receipt of this Policy, until you notify the Company of a withdrawal of this consent; or
- Your consent is given through your authorized representative such as a legal guardian, agent, or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent at any time. The Company will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain personal information or withdrawing consent for us to collect, use, or disclose your personal information could mean that we cannot provide you with our Services.
If you wish to withdraw your consent to use your information, please contact us using the information at the bottom of this Policy or the "Contact Us" section of the Website. Unless permitted by law to do so or for any of the legal reasons disclosed under this Policy, we will not collect, use, or disclose your information without your consent.
3. Types of information collected
We collect general types of information about you when you visit and use the Website; examples include personal information, content information, contact information, demographic information, behavioral information, sensitive information, and indirect information. Sometimes we collect combinations of these types of information.You are not statutorily obligated to provide us with any information when you access the Website or use our Services. However, without the required information, our provision of the applicable Service may be impossible (for example, if you do not provide your shipping information, it would be impossible to deliver any physical products you order from us).
3.1. Personal information
Personal information is any information that can be used to identify you or any other individual to whom the information may relate. You are prompted to provide us with this information. Such information may include your name, address, telephone number(s), mobile number, and/or email address, credit card number(s), bank account(s), or other unique information about you that you provide to us during the registration process, your placement of orders, your filling out of survey forms, or through the course of communicating with us. We may collect this same information about all other people when you provide it to us.
3.2. Demographic information
Demographic Information is information that may or may not be unique to you in the sense that it refers to selected population characteristics. Such information may include but is not limited to, zip code, mobile phone carrier, age, gender, salary range, education, marital status, occupation, the industry of employment, location, personal and online interests. We collect this information majorly when you fill out our questionnaire or survey forms.
3.3. Behavioral information
Behavioral information is information that is automatically collected pertaining to how you use the Website, the areas of the Website that you visit, what Services or features you access, and information about your computer hardware and software, including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet, and other websites you have visited. We collect this information using cookies, beacons, other tracking technologies, and third-party analytical tools (see below).
3.4. Content information
Content refers to your comments, feedback, reviews, testimonials, photos, or any material you submit on any of the Website or channels, especially if they are public facing. We may collect the information in your content, including certain personal information attached to them, and we may post them on some of the Website for marketing purposes.
3.5. Contact information
We collect your email address and phone number when you interact with us, including when you contact us for support, place an order for our products, or opt in to receive certain marketing communications from us.
3.6. Third-party information
Third-party information is information about you that we acquire from a third party which may include personal, demographic, behavioral, and indirect information. This collection may include but is not limited to, first-party cookies, third-party cookies, anonymous cookies, persistent identifiers, email opt-in, and search engine keywords. We have no access to or control over these cookies and other tracking devices used by third-party advertisers and networks. We have no responsibility or liability for the policies and practices of these parties.
3.7. Web technology information
3.8. Credit card and other payment method information
We may, in certain instances, collect credit card number(s), bank account information, and other payment method information, when you place an order for any of our products. When the credit card or other applicable payment method information is submitted to us, such information is encrypted and protected with Secure Socket Layer (SSL) encryption software. We will use the credit card information and other payment method information only for the purposes of processing and completing the transaction you requested. Such information will be disclosed to our third-party payment processor as necessary to complete the requested purchase transaction. This means that we do not store your payment method information in our database.
3.9. Sensitive personal information
Under applicable laws, such as the CCPA/CPRA, our collection of your bank account, credit card, and other financial information may be categorized as sensitive personal information. Where we collect your financial information, it will be used and secured in line with the required practices. Plus, this information is not stored in our database; it is collected and used by our third-party payment processors to process your payments.
3.10. No information from children
We do not knowingly collect any personal information from individuals under the age of 18, as our Services are not directly targeted at them. If we obtain actual knowledge that we have collected personal information about a person under the age of 18, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or disclose to third parties.
If your child has submitted his or her name through the Website, and you wish to communicate with us, please do so via [email protected] or the "contact us" section of the Website.
3.11. No protected health information
We do not collect information about past, present, or potential future medical conditions or treatments from users. And we are not a "covered entity" under the US’ Health Insurance Portability and Accountability Act (HIPAA) of 1996
4. Technologies used in collecting information automatically
Generally, we and our third-party service providers and supporting advertisers, use technologies such as cookies, web beacons, and java scripts. These technologies collect IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is used to analyze trends, administer the Website, track users’ movements through the Website, and gather demographic information about our user base as a whole. We may receive reports based on these technologies on an individual or aggregate basis.
4.2. Third-party cookies
Third-party cookies are those cookies that are used on the Website by third parties who perform certain tasks for us. These may include our advertising partners, analytics providers, payment processing partners, and security and fraud detection parties. Below are the possible third-party service providers we may use on the Website.
- We use AdWords Remarketing through Google which is a Remarketing and Behavioral Targeting service provided by Google, Inc. that connects the activity on the Website with the AdWords advertising network and the DoubleClick cookie, which collects information regarding certain patterns in your browsing history. To opt out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en.
- We also use Google Analytics which is an analysis service also provided by Google, Inc. Google utilizes the data collected through its cookies to track and examine the use of the Website, to prepare reports on their activities, and to share them with other Google services. You may opt out of the Google Analytics service using the Google Analytics opt-out add-on at https://tools.google.com/dlpage/gaoptout/.
- We also use Hotjar which records sessions and website visitors. Hotjar uses tracking codes installed in your browser to track your sessions with us, and we use these recordings to improve our performance and Services to you. Hotjar does not capture any sensitive data and often complies with applicable privacy laws by anonymizing interactions on the Website. You may opt out of Hotjar session recordings using the Hotjar Do Not Track option at https://www.hotjar.com/privacy/do-not-track/.
- We use the services of retention.com. They help us to gather the email addresses of visitors by deploying a code and matching the visitor with the email address they submitted on another website’s email list. You may opt out of retention.com tracking by visiting https://app.retention.com/optout.
4.3. Social media cookies
4.4. Web beacons
We use electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs or action tags) which allow us to collect information about your visit to the Website, measure and improve the effectiveness of advertisements and track the delivery of advertising. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, as well as a description of the page on which the web beacon resides. We may also use web beacons in email messages that we send to you. This allows us to determine if you opened or acted on the email messages. Because web beacons are the same as any other content request, you cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.
5. Our legal bases
We collect information about you when you access the Website or use our Services based on one or more of the following legal bases or grounds:
5.2. Contractual necessity
In other cases, we collect personal information from you to complete or fulfill a contract between us. For example, if you request to purchase any Services from the Website, we collect applicable information from you to enable us to complete the Service.
5.3. Legitimate interest
In some instances, we collect personal and non-personal information if we need it for our legitimate interest in ways that do not override any of your individual rights. For example, we collect device IP addresses, similar device properties, behavior, interest, and choices to identify you, detect fraud and violation, analyze and improve our Services, troubleshoot errors, and manage legal issues.
5.4. Legal obligation
In some cases, we may collect and retain personal information in compliance with legal obligations. For example, we may collect and retain transaction information because we are required by law to keep records.
6. Use of information
We use the information we collect when you access the Website and use our Services for the following purposes:
6.1. Providing our Services
We use the information we gather on the Website to provide you with the portion of our Services you have requested. This may include passing your information on to a third party to provide such Services. Although our contractual arrangement limits how this party can use your information, we do not control the privacy practices of third parties. If you have any questions or wish to remove your information from the third-party databases, you will need to contact that party directly.
6.2. Improving our Websites
We use the information we gather to respond to any inquiries you make, operate and improve the functionality of the Website, and deliver our Services as advertised on the Website. Our Services include the display of personalized products, content, and advertising, relating to your experience and interests.
6.3. Marketing purposes
Unless you have requested not to receive any marketing materials, we may also use (but will not disclose) your personal information to promote and market additional goods, services and special offers from us, our affiliates and/or our business associates including using direct marketing.You can choose not to allow us to use your personal information for direct marketing purposes by contacting us as outlined below (see "Your rights and choices" in section 12).Other uses of your information may include without limitation:
- To receive your order and ship the applicable product to your specified address;
- To process your payment for any product you purchase through the Website;
- To monitor violations of the Website and Services, including monitoring and detecting fraudulent practices;
- To comply with applicable laws;
- To personalize our Services to you based on your behaviors on the Website; and
- To fulfill any other purposes we define when we collect such information.
7. Disclosure of information
In summary, we will only disclose information about you to third parties to provide our Services, personalize your use, and comply with the law. These third parties and the circumstances in which we may share personal information with them include:
7.1. Service providers
We share your information with third parties who help us with the delivery of our Services you have requested. For example, your credit/debit card or any other payment method information you provide will be shared with applicable payment processors to enable them to process your payments and receive the Service you purchased.
7.2. Other website users
Information about your feedback, comments, reviews, testimonials, or any other content you provide to us on the Website, will be posted on public portions of the Website for marketing purposes with your consent. In most cases, the information concerned is aggregated or anonymous; however, in certain circumstances, the information shared may include your name, what you do, your picture, and your country of residence.
7.3. Ad partners
We may share information about user behaviors and other information collected through technologies with ad platforms to advertise our Services on their platforms. The information we share with these parties will not include any information you willingly provide to us. The information will only include those collected using cookies, beacons, third-party tools, and other technologies.
7.4. Law enforcement
We may disclose personal information if legally required to do so, or at our sole discretion, pursuant to a request from a government entity. This may include with respect to an ongoing investigation, a court order, or other legal summonses. Also, we may share personal information with another entity if it involves a case in which we need the information to protect our rights and properties, or those of other users or third parties.
7.5. Other entities in a business transaction
We may disclose and transfer your information to a third party that acquires any or all of our businesses, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of, such information in a transaction approved by the court.
8. Third-party collection and use
Third parties may independently collect and use information about you on or through the Website in the following ways:
Advertising agencies, advertising networks, and other companies who place ads on the Website, may use their own cookies, web beacons, and other technologies, to collect information about you, including your IP address, clicks, interests, preferences, geolocation, and similar information about your device. These parties may use the information collected strictly to send you adverts that match your behaviors.
The Website and email messages sometimes contain hypertext links to websites owned by third parties. We are not responsible for the privacy practices or the content of such other websites. These links are provided for your convenience and reference only. We do not operate or control any information, software, products, or services, available on these third-party websites. The inclusion of a link on the Website does not imply any endorsement of the services, products, or website, or its sponsoring organization.
As described in the earlier parts of this Policy, we use third-party tools to monitor, analyze, and report on the traffic to, from, and within the Website and email messages. These tools include Hotjar, retention.com, and Google Analytics, and the providers may collect analytics and analyze how you use the Website and other websites to send you targeted adverts.
9. How long we retain your information
Our policy regarding how long we keep your information on our database is: we retain the information collected, used, and disclosed for a minimum period of six months and a maximum period of one year from the latest date of your access, use, and purchase on the Website unless otherwise agreed upon.
Personal information collected through our online contact form becomes part of a contact list and is kept until you unsubscribe. When personal information has been used to make a decision about a specific individual, that information will be available to the individual for a minimum of six months and a maximum of one year from the date of the decision. In the event a request for personal information has been refused, the personal information relating to that request shall be retained for a minimum of six months and a maximum of one year from the date refusal was delivered, not received. Once collected information has expired, it will be destroyed, erased, or made anonymous.
We may retain information for longer periods in certain instances, including if we are required by law or if we need it to resolve an ongoing claim or disagreement.
10. Cross-border transfer of information
Although we process the information we collect from our base of operation in Canada and with our storage providers in the United States, we may transfer personal information to other third-party service providers in other countries and locations with varying privacy laws and practices from those of Canada, United States, and your location. However, we ensure that the third parties we transfer personal information to in connection with our Services practice strict global privacy practices like us.If you are providing us with information from locations with extra data protection requirements, such as locations under the GDPR, we apply the protection provided to you under those laws.
11. Storage and security of information
We keep the personal information we collect from the Website and Services at our storage service providers in Gilbert, AZ, USA. We may, from time to time, also hold personal information in connection with the purposes for which you provided your consent.
We endeavor to safeguard and protect your information. When you submit information on the Website, such information is protected both online and offline. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. The servers in which we store your information are kept in a secure physical environment. The servers have industry-standard firewalls. Access to such servers is password protected and access by our employees is limited.
Currently, we use Secure Socket Layer software ("SSL") to protect data and to secure any transactions. SSL encrypts information including credit card number(s), and names and addresses, as they are transmitted over the internet.
Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the internet can be guaranteed to be 100% secure. Therefore, we cannot and do not guarantee that your information will be absolutely secure. Any transmission of data at or through the Website is at your own risk. However, access to your information is strictly limited and not accessible to the public.
12. Your rights and choices
You have some of the following rights concerning the processing of your personal information under relevant privacy laws, including without limitation, PIPEDA, GDPR, and CCPA/CPRA.
- Accessing and correcting your information: To keep your personal information accurate, current, and complete, please contact us at [email protected] or use the "contact us" section of the Website. We will take reasonable steps to update or correct personal information in our possession that you have previously submitted via the Website.Where you request a correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
- Erasing your data: You may request that we erase the personal information we hold about you in the following circumstances:
- where you believe it is no longer necessary for us to hold the personal information;
- we are processing it based on your consent, and you wish to withdraw your consent;
- we are processing your data based on our legitimate interest and you object to such processing;
- you no longer wish us to use your data to send you marketing messages; or
- you believe we are unlawfully processing your data.
- Opting out of marketing communications: If you receive commercial/marketing emails from us, you may unsubscribe at any time by following the instructions contained at the bottom of the email. Likewise, you can opt out from receiving commercial messages sent to you via SMS by following the opt-out procedure provided in the SMS. If you are unable to opt out of commercial messages via the instructions provided on the applicable channel, you may reach out to us via our email address at [email protected] or any contact information on the Website.Please be aware that if you opt out of receiving commercial emails from us, it may take up to ten business days for us to process your opt-out request, and you may receive commercial messages from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages regarding the Website and Services.
- Opting out of targeted advertising: If you ever see any adverts about our Services on other platforms (such as Facebook, TikTok, and Google) because of an action you took on the Website, you can opt out by clicking https://optout.aboutads.info/ (if you are outside of the EU) or https://youronlinechoices.eu/ (if you are in the EU). Also, these third-party advertisers belong to self-regulatory groups, such as the Digital Advertising Alliance (DAA) and Network Advertising Initiative (NAI). These groups provide their own opt out mechanisms.
If you use our Services from locations under the GDPR, you have these additional rights:
Requesting data portability: You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used, and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of personal information or its processing once received by the third party.
Restricting us from processing personal information: You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:
- You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
- We wish to erase the personal information, but you want us to simply restrict the use of that data;
- We no longer need the personal information for the processing, but you require us to retain the data for the establishment, exercise, or defense of legal claims; or
- You have objected to us processing personal information we hold about you based on our legitimate interest, and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
Objecting processing: You have the right to object to our processing of data about you and we will consider your request. Please provide us with details as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it concerning legal claims.You also have the right, at any time, to object to our processing of data about you to send you marketing messages, including where we build profiles for such purposes, and we will stop processing the data for that purpose.
Reporting us: If you believe that we are unlawfully processing your information as opposed to the information in this Policy, you may report us to any data protection authority in your geographic location
13. Users in California
If you are using our Services from California, you have these additional disclosures and rights under the CCPA/CPRA and similar laws.Few things to note:
- We do not sell, rent, or share personal information about you with third parties for them to market their products or services to you. However, we may market products and services from our affiliates to you if you subscribe to our email marketing list.
- We will not discriminate against you if you try to exercise any of the rights available to you under the CCPA/CPRA. Unless permitted by the CCPA/CPRA or other applicable law, we will not:
- Deny you access to the Website.
- Charge you different prices or rates on the Website, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of Services on the Website.
- Suggest that you may receive a different price or rate for Services or a different level or quality of Services on the Website.
- Where you provide your credit card or other financial information, it will be used by the applicable third-party payment processor to process your payments, and adequate security will be used to keep your information secure from unauthorized access.
- In addition to the rights provided generally to users of our Services, you have the right, under the CCPA/CPRA, to know about the categories of personal information we collected about you in the past 12 calendar months and the sources of that information, as well as its uses and the third parties with whom we share them with (please, see below).
Categories of information collected
We have collected the following categories of information in the past 12 calendar months:
- Identifiers, such as your name, email address, phone number, device IP address, location, and photo;
- Commercial information, such as your purchase history, including Services purchased, the amount paid, and the like;
- Visuals, such as the photos you provide along with your reviews, testimonials, and feedback;
- Internet and network activities, such as your behaviors, interest, search terms, and pages viewed;
- Professional information, such as the type of health services a professional intends to purchase our Services for;
- Sensitive information, such as your credit card and other financial information; and
- Location and geolocation, such as your shipping address and geolocation from your IP Address
Sources of the information collected
We collect the above information directly from you, via technologies, and third-party sources.
Uses of the information collected
We use the information collected for the purposes stated in section 6 (Use of information) of this Policy.
Sharing of the information collected
We may share the categories of information with the following third parties:
- Third-party service providers who perform some of our Services for us (for example, your credit card information is shared with our payment processor to enable them to process your payments);
- If you submit reviews, testimonials, or feedback about our Services, they may appear on the Website for marketing purposes and visitors may see them; and
- We share certain information obtained through technologies with our advert partners for them to help us advertise our Services on their platforms.
You may also exercise any of your rights by submitting a request, including your full name, means of identification, and a brief explanation of your request to [email protected] or the contact information provided below. We shall comply with your request in less than ten (10) business days provided your request does not prove impossible or involves disproportionate effort for us to comply.
14. Users in Nevada
If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that personal information to additional third parties. Fortunately, we do not currently sell your personal information as defined by Nevada law, and we do not have plans to do so in the future. However, you can opt out of any future sale of your information by messaging us at [email protected]. We may require additional information from you to verify your identity and process your request. We will respond to your request within the time required by Nevada law.
15. Do Not Track signals
We currently do not respond to "Do Not Track" signals sent by your browser or other mechanisms that provide users with the ability to exercise choice regarding the collection of personal information about your online activities over time and across third-party websites or online services. Our third-party service providers, including those that provide advertising and analytics services, may collect information about your online activities over time and across different websites or online services when you use the Website.
16. Changes to Policy
We reserve the right to make material changes to the substance of this Policy. We will post those changes through a prominent notice on the Website so that you will always know what information we gather, how we might use that information, and to whom we will disclose it. Your continued access and use of the Website and Services after any changes to this Policy shall constitute your agreement with the changes made.
17. Other agreements
Your use of our Services is also conditioned upon your reviewing and agreeing to other agreements and policies contained on the Website. Other agreements include, without limitation, our Terms of Service, Refunds, and Canceling policies and agreements.
18. Contacting us
You may contact us with questions, comments, or complaints regarding this Policy and practices by using the "Contact Us" section of any of the Website.